Newly Identified Compliance Risks Due to COVID-19: What You Should Know WHAT HAPPENED? Last week, the Office of Compliance Inspections and Examinations of the United States Securities and Exchange Commission (OCIE) issued a Risk Alert which outlines new compliance risks stemming from the global pandemic. The SEC and OCIE have remained [...]
Open-End Funds: Proposed Amendments to Reporting and Disclosure Requirements WHAT HAPPENED? On Aug. 5, 2020, the United States Securities and Exchange Commission proposed a new set of amendments to mutual fund and exchange-traded fund disclosure requirements. The package includes, among other things, changes to visual presentation requirements and the [...]
SEC Adopts Rule Amendments, Issues Guidance on Proxy Voting Process WHAT HAPPENED? On July 22, 2020, the United States Securities and Exchange Commission adopted rule amendments and issued additional guidance on the proxy voting responsibilities of investment advisers and third-party proxy voting advice service providers. The goal of the [...]
Are You Taking Steps To Avoid Ransomware Attacks? WHAT HAPPENED? Earlier this month, the Office of Compliance Inspections and Examinations of the United States Securities and Exchange Commission (OCIE) issued a Risk Alert which outlines best practices for maintaining a secure network; the United States Cybersecurity and Infrastructure Agency [...]
New Security Feature for Web CRD and IARD Systems WHAT HAPPENED? For Super Account Administrators (SAAs) and Account Administrators (AAs) on FINRA’s Web CRD or IARD platforms, a new security feature is now required as part of the login process. For these administrators, FINRA is phasing in a multi-factor [...]
SEC Proposes Changes to Form 13F WHAT HAPPENED? On July 10, 2020, the United States Securities and Exchange Commission proposed amendments to Form 13F reporting. The changes would affect the filing threshold for institutional advisers and several other requirements. Because the filing requirements have not been updated since adoption [...]
Nine Things to Notice: SEC Examiners’ Focus Areas WHAT HAPPENED? As capital markets shift and the risks to market participants change, so do the focus areas of routine SEC exams. Below are trending items from recent examinations: KEY FOCUS POINTS: Environmental, social, and governance [...]
LIBOR Transition Compliance Risks WHAT HAPPENED? On June 18, 2020, the Office of Compliance Inspections and Examinations of the United States Securities and Exchange Commission (OCIE) announced an exam initiative and issued a subsequent Risk Alert about LIBOR transition preparedness. LIBOR, formerly known as the London Interbank Offered Rate, [...]
OCIE: Private Fund Risk Alert WHAT HAPPENED? On June 23, 2020, the Office of Compliance Inspections and Examinations of the United States Securities and Exchange Commission (OICE), released a Risk Alert which outlines recently observed compliance issues among private fund advisers. Over a third of SEC-registered advisers manage private [...]
Our Firm Filed Form CRS - What Now? WHAT HAPPENED? Initial filings of Form ADV Part 3 (Form CRS) are due by June 30, 2020. For months, retail advisers and their service providers have put much time and effort into understanding, writing, and filing the initial Form CRS document. [...]