Episode 80: Vital Considerations for Conducting an Annual Review
On episode 80 of the CCO Buzz, Core Compliance discuss vital considerations for conducting an Annual Review.
A Change in State Oversight Prompts California’s Investment Advisors to Review Their Policies and Procedures
To help strengthen the state’s consumer protection laws and oversight of the financial industry, California has passed legislation that has changed the name of the Department of Business Oversight (DBO) to the Department of Financial Protection and Innovation (DFPI) and … Read More
IAA Compliance Corner: How to Improve Your Compliance Program
CEO Michelle Jacko’s article, “How to Improve Your Compliance Program,” was published in the October 2020 issue of the Investment Adviser Association’s (IAA) Compliance Corner Newsletter. In the article, Ms. Jacko provides readers with additional ways to improve their Compliance … Read More
Preparing for the U.S. Department of Labor’s Proposed Clarification on ERISA Proxy Voting
On August 31, 2020, the U.S. Department of Labor (DOL) released a proposal under the Employee Retirement Income Security Act of 1974 (ERISA) to amend fiduciary duties regarding proxy voting and shareholder rights. This particular rule is only in the … Read More
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