Top 6 SEC Compliance Deficiencies

Did you know?   1. Compliance Rule 2. Disclosure 3. Fiduciary Duty 4. Code of Ethics 5. Advertising Rule 6. Custody Rule   This fact was presented by the SEC’s Office of Compliance Inspections and Examinations’ (OCIE’s) assistant director, Renee … Read More ›

Compliance Program: Tools & Tips

  By Monica Bullard, CPA, CSCP Managing Member Focus 1 Associates LLC           Important items to note: Material changes to the 2016 Program Template are outlined in the Executive Summary Tab, under “First Quarter Review.” Example … Read More ›

Improving Compliance Adoption

  Historically, Focus 1’s compliance training efforts were centered on an adviser and its CCO’s responsibility of designing and implementing an effective compliance program. As per the Compliance Rule, “An adviser’s chief compliance officer should be competent and knowledgeable regarding … Read More ›

ReTIRE Initiative – OCIE’s June 22nd Risk Alert

OCIE, through the National Examination Program (NEP), will conduct examinations of SEC-registered investment advisers and broker-dealers (collectively, “registrants”) under the Retirement-Targeted Industry Reviews and Examinations (“ReTIRE”) Initiative that will focus on certain higher-risk areas of registrants’ sales, investment, and oversight … Read More ›

Whistleblower Exam

  We have heard that the Boston Regional Office of the SEC has begun a whistleblower review which apparently is being conducted as a correspondent exam. This means the staff is doing the reviews by gathering documents without visiting firms. … Read More ›