In February of 2022, the SEC proposed Cybersecurity Risk Management Rules and Amendments (the “Proposed Rules”) that continue to focus on cybersecurity risks as an unavoidable reality for the financial markets and, specifically, for registered investment advisers who “increasingly depend … Read More
As the world of compliance in the investment advisory and broker-dealer spaces continues to evolve and the scope of required services expands, compliance professionals in the industry are leveraging technology and third-party vendors more than ever to meet the demands … Read More
When a regulator shows its hand, take it seriously—a poignant lesson that one is wise to heed. At the end of January, the Securities and Exchange Commission (“SEC”) released a Risk Alert entitled ‘Observations from Broker-Dealer Examinations Related to Regulation … Read More
In today’s electronically connected world, more and more exchanges are happening online, in terms of both sensitive information and currency. Be it communication through social media platforms, mobile applications, email, and text messages, or even the purchase and delivery of … Read More
Several years ago, the SEC initiated the CCOutreach program, now called the Compliance Outreach Program, to promote open communications and coordination among various industry related entities – mutual funds, investment advisers and broker-dealers – on compliance issues. The program was … Read More
$18 trillion in private fund assets is managed by 35% of all SEC-registered investment advisers which is a notable 70% increase from the prior five years. To that end these advisers unfortunately are riddled with many compliance issues observed by … Read More
It’s the time of year again where Chief Compliance Officers start thinking about the compliance tasks that need to be completed by year-end, and there’s a lot to think about this year. Importantly, 2022 carries compliance deadlines for two major … Read More
At the onset of the pandemic in early 2020, firms were forced to pivot quickly into a remote working environment. While business continuity plans had been repeatedly tested for a shift in location from the primary location, no one understood … Read More
The implementation of technology has become an integral component in the administration of a compliance program. Gone are the days of maintaining hardcopies in filing cabinets and conducting manual reviews of compliance tests. Similar to the adoption of technology in … Read More
Regulators are continuing their focus on robo-advisers,[1] and since 2018 the Securities and Exchange Commission (“SEC”) has filed several enforcement actions reflecting violations of various regulations under the Investment Advisers Act of 1940 (“Advisers Act”).[2] The most reoccurring are violations … Read More