In June 2010, the SEC adopted Rule 206(4)-5 of the Investment Advisers Act of 1940, which addressed “pay-to-play” practices surrounding political contributions. Pay to play is a term used in the financial industry that generally refers to investment advisers making … Read More
2016 is speeding to a close, so to assist advisory firms in preparing for year-end compliance requirements, along with certain upcoming regulations, Core Compliance & Legal Services, Inc. (“Core Compliance”) recently published a Risk Management Update (“RMU”) that contains a … Read More
The Compliance Program
Recently, the London-based public accounting firm Ernst & Young, along with a senior partner and an auditor agreed to pay approximately $9.3 million in settlement charges after SEC investigations determined that there had been violations of auditor independence rules. According … Read More
On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule on customer due diligence (the “CDD Rule”). This rule addresses new and existing due diligence requirements for Covered Financial Institutions (as defined in the rule), which … Read More
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
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 today’s world, emails are the main avenue of communication, both for personal and business purposes. However, accompanying that is the fact that email hacking has become more commonplace and hackers continue to find sophisticated ways to obtain illegal access.