National Examination Program’s 2015 Priorities
In the last Core Compliance blog post, we highlighted our 2015 Compliance Predictions, shortly before the Securities and Exchange Commission (“SEC”) released the National Examination Program’s priorities for 2015. The list, which is relatively short compared to previous years’, … Read More
The Dangers of Recidivist Deficiencies and the SEC’s Compliance Program Initiative
December 2014 “In the past few years, the Securities and Exchange Commission (“SEC”) has taken a tougher stance against recidivist behavior by registered investment advisory firms (“RIAs”). Recidivism refers to occurrences where an RIA has not corrected deficiencies noted in … Read More
Compliance Failures Cost Firm $15 Million
On September 23, 2014, the Securities and Exchange Commission (“SEC”) charged Barclays Capital Inc. (“Barclays”), a global banking services firm, with “failing to maintain an adequate internal compliance system.” After acquiring Lehman Brothers, a financial services firm that filed for … Read More
The Office of the Investor Advocate Speaks on “User Fees” from RIAs
The Securities and Exchange Commission (“SEC”) recently created the Office of the Investor Advocate “to ensure that the concerns of investors are appropriately considered as decisions are being made and policies are being adopted at the Commission, at self-regulatory organizations, … Read More
Soft Dollar Arrangements Once Again Headline SEC Enforcement Efforts
A San Diego-based investment firm and two of the firm’s advisers have been charged with misusing soft dollars and “cherry-picking” more favorable trades to certain clients. Securities and Exchange Commission (“SEC”) Administrative Law Judge Brenda P. Murray ruled that the … Read More
Alternative Mutual Fund Exam Sweep
Last month the director of the Securities and Exchange Commission’s (“SEC’s”) Division of Investment Management, Norm Champ, spoke to the Practicing Law Institute’s Private Equity Forum regarding an upcoming national sweep of alternative mutual funds. It is expected that the … Read More
