Episode 79: Are You Prepared for a Cybersecurity Sweep Exam?
On episode 79 of the CCO Buzz we discuss what firms should consider when preparing for a Cybersecurity Sweep Exam.
How to Prepare for a Cybersecurity Sweep Exam
Cybersecurity continues to be a top priority for the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations’ (“OCIE”), especially as the bulk of firms have had to shift to working remotely in light of COVID-19. Just in … Read More
What CCOs and Compliance Departments Need to Know About the SEC’s New Definition of ‘Accredited Investor’
Not long ago, the ability to invest in private offerings in the U.S. was limited to those whose annualized income and net worth afforded a country-club lifestyle. The requirements were an average income of $200,000 for the last two years … Read More
Your Annual Review: Cybersecurity and Privacy
The annual review is one of the three (3) pillars of Rule 206(4)-7 (“the Compliance Rule”) of the Investment Advisers Act of 1940 (“the Advisers Act”). The rule requires SEC-registered investment advisers (“RIAs”) to annually review “the adequacy of the … Read More
SEC Charges Birinyi Associates, Inc. with Unfair Trade Practices and Compliance Failures
On July 31, 2020, the Securities and Exchange Commission (“SEC”) announced it was charging Connecticut-based investment adviser, Birinyi Associates, Inc. (“BA” or the “Firm”), with violations of Sections 206(2) and 206(4) and Rule 206(4)-7 thereunder (“the Compliance Rule”) of the … Read More
NSCP Currents: State Advisers – Important Information to Prepare for a Regulatory Exam
Managing Director, Consultation Services Tina Mitchell’s article, “State Advisers – ImportantInformation to Prepare for a Regulatory Exam,” was published in the July 2020 edition of the National Society of Compliance Professionals’ Currents newsletter. In the article, Ms. Mitchell discusses regulations that can … Read More
SEC Charges Valic Financial Advisors in Two Separate Actions with Disclosure Failures and Mutual Fund Selection Violations
On July 28, 2020, the Securities and Exchange Commission (“SEC”) announced it was charging Houston-based financial services firm, Valic Financial Advisors, Inc. (“VFA” or the “Firm”), a dually registered broker-dealer and investment adviser, in two separate actions for violations of … Read More
NSCP Webinar: Forward Thinking: New Cybersecurity Considerations for 2020 and Beyond
August 4, 2020 @ 11:00 AM PST/2:00 PM EST | Speakers: Core Compliance and Nicole Dragoo
SEC Releases Risk Alert on Cybersecurity and Ransomware Attacks
On July 10, 2020, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) released a risk alert highlighting a recent increase in ransomware attacks against financial industry participants. The risk alert highlights the importance for financial … Read More
Registered Investment Advisers – Time to Revisit your Disclosures?
Proper Disclosures are a Fiduciary Responsibility One of the most important fiduciary duties of a Registered Investment Adviser (“RIA”) is that of disclosure. Current regulations require disclosure of many aspects of a RIA’s business including, among many things, ownership, business … Read More