September 15 , 2016 – Wolters Kluwer Modern Compliance
CEO, Michelle Jacko and consultant Tina Mitchell will be presenting: Chapter on Due Diligence.
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
SEC Alerts Registered Advisers About Share Class Exam Initiative
On July 13, 2016, the Securities and Exchange Commission (“SEC”), through their Office of Compliance Inspections and Examinations (“OCIE”), issued a Risk Alert outlining their exam initiative on risks and conflicts pertaining to investment adviser recommendations of mutual funds and … Read More
The Investment Advisers Modernization Act of 2016
On June 16th, the House Financial Services Committee approved H.R. 5424, the “Investment Advisers Modernization Act of 2016.” The proposed bill primarily provides relief to private fund advisers, but also includes provisions applicable to investment advisers that don’t manage private … Read More
The DOL Conflicts of Interest Rule and How it May Affect You (Part 2)
Who is an ERISA Fiduciary?
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
SEC Takes Advisory Firm to Enforcement for Failing to Deem a Third Party Consultant as an “Access Person”
In the Matter of Federated Global Investment Management Corp (“FGIMC”), the SEC settled an administrative proceeding against FGIMC for a failure to establish, maintain, and enforce written policies and procedures reasonably designed to prevent the misuse of material, nonpublic information … Read More