Since 2014, the Securities and Exchange Commission (“SEC”) has been talking about proposing requirements for SEC registered investment advisers to obtain third party compliance reviews. The more recent being in Chairman Mary Jo White’s testimony given to the U.S. Senate … Read More
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
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
In a keynote address given to the Investment Company Institute during their 2016 General Meeting, the Securities & Exchange Commission (“SEC”) Chair Mary Jo White provided not only an overview of current areas of interest and proposals affecting mutual funds, … Read More
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
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
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Warren Buffet on Derivatives “In my view, derivatives are financial weapons of mass destruction, carrying dangers that, while now latent, are potentially lethal.” ~ Excerpt from the 2002 Berkshire Hathaway Annual Report Buffet’s comments were particularly prescient six years later … Read More