5 Types of Documentation You Should Be Reviewing Annually
With 2017 rapidly coming to a close, you’re probably thinking about Christmas and your end-of-year vacation. You also may be putting the last touches on your company’s annual review. The Securities and Exchange Commission (“SEC”) has required advisory firms to … Read More
Annual Reviews: Suggestions for Compliance Best Practices
Annual reviews need to be done at least once every year or even more often. Some firms conduct reviews every quarter, rather than just once a year. For investment advisers registered with the Securities and Exchange Commission (“SEC”), annual reviews … Read More
Why Those Free to Download Annual Compliance Review Checklists Aren’t Good Enough
It’s tempting, I know, to want to search online for a compliance review checklist you can simply download for the required annual review. Among the many requirements within the Investment Advisers Act of 1940, the annual compliance review requirement in … Read More
3 Common Mistakes Investment Advisory Firms Make When Maintaining Compliance Programs
Regardless of size, investment advisers need to be aware of some common, and avoidable, mistakes that are often made when maintaining compliance programs. Some of these mistakes are at a high level, things that senior management should be aware of. … Read More
How Robust is Your Annual Review Process?
Federal regulations require investment advisers and registered investment companies to review their compliance policies and procedures annually to ensure adequacy. Core Compliance & Legal Services, Inc. recently published a Risk Management Update (“RMU”), which discusses Securities and Exchange Commission (“SEC”) … Read More
Enhancing Annual Reviews – Practical Considerations for Investment Advisers and Investment Companies
It’s been over a decade since the Securities and Exchange Commission (“SEC”) adopted Rule 206(4)-7 under the Investment Advisers Act of 1940, and Rule 38a-1 under the Investment Company Act of 1940. Despite the passage of time, Rule 206(4)-7 and … Read More
Robo-Advisors Come Under SEC Scrutiny
During a speech given yesterday at the SEC-Rock Center for Corporate Governance, Securities & Exchange Commission (“SEC”) Chairperson Mary Jo White discussed how the SEC’s National Exam Program are examining robo-advisors for adherence to requirements under the Investment Advisers Act … Read More
Inaccurate Trade Data Costs Firm $4.25 Million
On July 14, 2015, the Securities and Exchange Commission (“SEC”) brought an enforcement action against OZ Management LP (“OZ”), an SEC-registered investment adviser for giving inaccurate trade information to certain broker-dealers. The SEC’s final order, which was issued upon OZ’s … Read More
Three Advisory Firms Charged with Violating SEC Custody Rule
The Securities and Exchange Commission (SEC) rounded out a busy month of issuing enforcement actions by charging three investment advisory (IA) firms with violations of Section 206(4) and Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Custody Rule”). … Read More