Creating a Robust Compliance Program
The Compliance Program
Mary Jo White Stepping Down as Chair of Securities and Exchange Commission
On November 14, 2016, Mary Jo White, SEC Chair, announced her plans to step down at the end of the Obama Administration. During her tenure, the SEC brought more than 2,850 enforcement actions and obtained judgements and orders that tallied … Read More
2016 Core Compliance Annual Compliance Symposium Materials
Thank you for attending our 5th Annual Compliance Symposium in Anaheim, CA. We hope you enjoyed meeting the team and were able to gain valuable insight into the changes impacting our industry today. In keeping with cybersecurity best practices, we … Read More
Department of Labor Issues First Set of FAQs on DOL Fiduciary Rule
On October 27, 2016, the DOL issued highly anticipated guidance on the Conflicts of Interest Rule in the form of FAQs that address the exemptions. The Director of the Employee Benefits Security Administration (“EBSA”), Phyllis Borzi, indicated this is the … Read More
SEC Files Complaint Against Former Professional Football Player
On August 10, 2016, the SEC filed a complaint in federal court against Merrill Robertson Jr., a former Philadelphia Eagles football player, with defrauding investors. Mr. Robertson, along with Sherman C. Vaughn, Jr., and the company they co-owned, Cavalier Union … Read More
What to Expect When the SEC Proposes Requirements for Advisers to Obtain Third Party Compliance Reviews
Since 2014, the Securities and Exchange Commission (“SEC”) has been talking about proposing requirements for SEC registered investment advisers to obtain third party compliance reviews. The more recent being in Chairman Mary Jo White’s testimony given to the U.S. Senate … Read More
September 15 , 2016 – Wolters Kluwer Modern Compliance
CEO, Michelle Jacko and consultant Tina Mitchell will be presenting: Chapter on Due Diligence.
FinCEN Issues FAQs Pertaining to their Final Rule Under the Bank Secrecy Act
On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule on customer due diligence (the “CDD Rule”). This rule addresses new and existing due diligence requirements for Covered Financial Institutions (as defined in the rule), which … Read More
SEC Proposed Business Continuity & Transition Plan Rule: More than Just Disaster Recovery Planning
On June 28, 2016, the Securities and Exchange Commission (“SEC”) issued a proposal requiring SEC registered investment advisers to implement a written business continuity and transition plan (“BCTP”).1 In the corresponding press release,2 the SEC stated that the purpose of the … Read More
SEC Says Investment Advisers Need to Think About Transition Planning
The Securities and Exchange Commission (“SEC”) recently issued proposed Rule 206(4)-4 under the Investment Advisers Act of 1940, as amended (“Advisers Act”), requiring registered investment advisers to have written plans addressing business continuity and transition (wind down) steps in the … Read More