Phasing Out LIBOR WHAT HAPPENED? First, what is LIBOR? The London Interbank Offered Rate ("LIBOR") is the average interest rate by which major global banks borrow from one another. LIBOR rates that are not based on the U.S. Dollar will be discontinued on December 31, 2021, while those linked to the [...]
STAYING VIGILENT DURING THE HOLIDAYS WHAT HAPPENED? While you are planning for holiday parties and traveling, malicious cyber actors are making different plans. Recently, CISA and the FBI have seen that this time of year is when these actors look to disrupt critical networks and systems belonging to organizations, businesses, and [...]
SonicWall Usage WHAT HAPPENED? SonicWall is strongly urging organizations that use SMA 100 series appliance to immediately patch them against multiple security flaws rated with CVSS scores ranging from medium to critical. If left unpatched, one of the vulnerabilities may be exploited to remotely takeover unpatched devices. [...]
SEC Focuses on Advisory Fee Calculation: What You Need to Know WHAT HAPPENED? During recent regulatory exams, the SEC detected several issues with investment advisers’ fee calculations. The SEC wants to see that firms have: Adopted, and are following, policies and procedures that adequately address fair and accurate charging of fees; [...]
Advisers to Private Funds: Going from Exemption Reporting Adviser (ERA) to Fully Registered Adviser. Fairview partners with firms to get registered and provide on-going compliance support. WHAT IS GOING ON? Many exempt reporting advisers (ERAs) are unaware of their current compliance responsibilities as well as what triggers full registration, the timing for [...]
New Enforcement Date for DOL Rollover Recommendations: Documenting and Meeting the DOL’s Prohibited Transaction Exemption WHAT HAPPENED? The recent Department of Labor Field Assistance Bulletin 2021-02 provides that from December 21, 2021, through January 31, 2022, the DOL will not pursue prohibited transaction claims against firms who are working diligently, and in [...]
Beware of BlackMatter WHAT HAPPENED? BlackMatter is ransomware-as-a-service tool that allows ransomware developers to profit from cybercriminal affiliates, such as BlackMatter actors, who deploy against victims. These actors have attacked numerous U.S. based organizations and have demanded ransom payments ranging from $80,000 to $15,000,000 in Bitcoin and Monero. BlackMatter may be [...]
Family Matters: The Family Office Exemption from SEC Registration Could Change WHAT HAPPENED? Recently, U.S. Congresswoman, Alexandria Ocasio-Cortez introduced The Family Office Regulation Act of 2021 (4620) to amend the Investment Advisers Act of 1940 to require regulatory oversight of family offices. The proposal aims to limit the exemption to family offices with less [...]
Apple Device Updates WHAT HAPPENED? Apple owners: Time to update your software. Apple has uncovered evidence that attackers may be actively exploiting two vulnerabilities in company software to take over certain Apple devices, including iPhones.The company issued the security patches last week while warning the vulnerabilities could lead to remote code execution. [...]
The SEC Suits Up for Suitable Recommendations WHAT HAPPENED? The SEC has recently started cracking down on investment advisers improperly recommending complex financial products. In a recent case, the SEC found that the adviser had not adopted and implemented any written policies and procedures to prevent these types of recommendations from [...]