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
We have had several clients who have had SEC exams recently despite the social distancing measures in place across the United States. Yes, they were
COVID-19 has forced a new, global reality upon us. The breadth has yet to be fully comprehended. One of the new realities is the significant
With the best intentions, on January 7th, the Securities and Exchange Commission’s (“Commission”) Office of Compliance Inspections and Examinations (“OCIE”) shared the National Exam Program
Today the SEC Division of Enforcement released its 2019 Annual Report for the fiscal year ended this past September. The recap shows that enforcement actions
SEC staff recently published their FAQs regarding financial conflicts and adviser compensation. While not carrying the full weight of formal rulemaking, the guidance provides useful
