Registered investment companies (“RIC”) are regulated entities subject to various securities laws. One main regulation is Rule 38a-1 under the Investment Company Act of 1940, as amended (“40 Act”), which requires a RIC to adopt and implement a compliance … Read More
On episode 78 of the CCO Buzz, our Senior Compliance Consultant discusses Rule 38a-1 under the Investment Company Act of 1940 and the requirements within compliance programs for Registered Investment Companies. (GUITAR INTRO) CCO Buzz: Hello and welcome back to … Read More
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
On July 2, 2020, the North American Securities Administrators Association (“NASAA”) released a notice for public comment on its proposed model rule for investment adviser written policies and procedures (“the Model Rule”) under the Uniform Securities Acts of 1956 and … Read More
On June 29, 2020, the U.S. Department of Labor (DOL) proposed its new class exemption rule (the “Rule”) designed to replace the 2016 Best Interest Rule that was vacated by the U.S. Court of Appeals for the Fifth Circuit (“the … Read More
On episode 76 of the CCO Buzz, Core Compliance discusses how to make the most of your Annual Review through simultaneous testing opportunities.
Under Rule 206(4)-7 (“Compliance Rule”) of the Investment Advisers Act of 1940 (“Advisers Act”), Investment Advisers (“RIAs”) that are registered with the Securities and Exchange Commission (“SEC”) must perform an annual review of the RIA’s policies and procedures (“P&Ps) to … Read More
On June 1, 2020, the National Futures Association (“NFA”) permanently barred Hong Kong-based commodity pool operator Bainbridge Asia Limited (“BAL” or the “Firm”) and its sole principal and associated person, Wai Man Yip, from membership and acting as a principal … Read More
On May 26, 2020, the Securities and Exchange Commission (“SEC”) announced that Los Angeles-based private equity firm and registered investment adviser, Ares Management LLC (“Ares” or the “Firm”) agreed to a cease-and-desist order, censure, and to pay a $1 million … Read More
On episode 71 of the CCO Buzz we discuss compliance considerations for robo-advisers.