On April 25, 2016, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management issued a no-action letter to the Investment Adviser Association (“IAA Letter”) giving relief to certain sub-advisers from surprise audits requirements under Rule 206(4)-2 under the Investment … Read More
The final adopting release of the Department of Labor’s (“DOL”) Conflicts of Interest rule (the “Rule”),1 along with the separate releases of two new and four amended prohibited transaction exemptions (“PTE”) are now published in the Federal Register as of April … Read More
On April 19, 2016, the Securities and Exchange Commission (“SEC”) held their National Compliance Outreach seminar, which covered a number of topics, including:
During her testimony to the U.S. Senate Subcommittee on Financial Services and General Government Committee on Appropriations, Chair White outlined the SEC’s top priorities for allocating the additional funding requested under their fiscal year 2017 (October 1, 2016, through September … Read More
On April 6, 2016, the Department of Labor’s (“DOL”) proposed rule expanding the definition of the term “fiduciary” and addressing certain conflicts of interest was adopted and published (the “DOL Conflicts Rule”). While the final rule is not as extensive … 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
In January, the Securities and Exchange Commission’s (“SEC’s”) Office of Compliance Inspections and Examinations (“OCIE”) issued their annual examination priorities update, which is focused on the highest perceived risks to investors and the U.S. capital markets for the coming year.1 … Read More
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