Electronic Communications–What Should CCOs Be Asking?
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
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
SEC3 has contributed articles to two recent issues of NSCP Currents, including a breakdown of 2018’s Share Class Selection Disclosure Initiative and a broader look
Last week, the SEC shared feedback in a Risk Alert, Observations from Examinations of Investment Advisers: Compliance, Supervision, and Disclosure of Conflicts of Interest (“
On May 23, 2019 the Office of Compliance Inspections and Examinations (“OCIE”) issued a risk alert identifying frequent security risks associated with the storage of