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
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
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
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
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
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
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
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
The Securities and Exchange Commission (SEC)’s Division of Investment Management released detailed guidance this month responding to compliance oversight findings issued in a report by the SEC’s Office of the Inspector General (OIG). The original OIG report, released on June … Read More
The recent SEC release of exam priorities serves as a helpful reminder that broker-dealer (BD) and investment advisory (IA) firms should ensure they are prepared when the SEC comes knocking. Below are some steps that you may want to consider in … Read More