Investment Advisers that serve retail investors are required to maintain Form CRS and deliver it to each such retail investor. According to Rule 204-5 of
As we wrote last month, the SEC has been full throttle in targeting firms for enforcement for failing to file and deliver Form CRS where
SEC staffers have long asserted that their efforts are informed by a risk-based assessment in selecting registrants for examination. A key component of this has
The SEC is full throttle ahead currently targeting multiple firms for enforcement related to failure to file Form CRS. The SEC originally gave companies some
New York recently adopted new regulations covering registration and examination requirements for investment advisers and their representatives. Notably, these requirements are applicable both to investment adviser
December 23, 2020 The SEC finally adopted their long-awaited modernization to investment adviser marketing rules. The adopting release can be found here, and the language of
We want to take the opportunity to share a few significant items put out by the SEC last month. Enforcement Annual Report On November 2,
We promised to revisit COVID-19/pandemic specific risks for the near future given we know all current SEC exams are considering these risks. Our last communique
We promised last week to help you dissect your compliance program to be sure you are ready to answer related questions from regulators and institutional investors. Let’s
In a release on August 12, 2020, the SEC’s Office of Compliance Inspections and Examinations identified specific COVID-19-related issues, risks, and practices relevant to investment
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