Building a Defense Against Cyber Fraud – Hour Webinar

Learn how to tackle cyber threats and protect your firm against IT security breaches.  The session explores the regulatory landscape, discusses key steps in establishing internal controls, and helps set you on a pathway for a successful business continuity plan. Other … Read More ›

Simons Says: 2014 Year-End Review

    In November, the SEC issued its 2014 Agency Financial Report.  Not exactly exciting reading, except for Management’s Discussion and Analysis (“MD&A”). In MD&A, we can skip down to an area that directly impacts us: FY 2014 Year in … Read More ›

Simons Says: You Might Not Realize You Have Custody

Based on deficiency letters that we have seen over the past year and especially in the past few months, it appears that many advisers either didn’t believe that the SEC Staff was serious about looking closely at the adequate safekeeping … Read More ›

Record-Breaking SEC Enforcement Actions in FY2014

Record 755 enforcement actions, covering a wide range of misconduct, vs 686 enforcement actions in FY2013 and 734 enforcement actions in FY2012 Obtained orders totaling $4.16 billion in disgorgement and penalties, vs $3.4 billion in FY2013 and $3.1 billion in … Read More ›

Additional Insight on Code of Ethics Questions

Q: Does Rule 204A-1 require reporting on company sponsored (or not sponsored, such as for a spouse) 401(k) plans if the asset type needs to be reported? To answer your question, first we will step back to the requirements. Rule … Read More ›

Guidance on Email Reviews

  Although the SEC expects advisers to conduct email reviews as part of the adviser’s compliance program under Rule 206(4)-7, the Commission and its Staff have not offered much guidance with regard to what that review should entail, including the sample size.  So … Read More ›

FATCA – A Practical Perspective

Description Presented Thursday, September 25, 2014 The Foreign Account Tax Compliance Act (FATCA) is U.S. legislation enacted by U.S. Congress to prevent tax evasion by U.S. persons through the use of foreign accounts and to assist the IRS in identifying … Read More ›

Simons Says: Déjà vu All Over Again

I read something the other day that I want to share, “It will take over 24 million man hours to comply with Dodd-Frank rules per year. It took only 20 million to build the Panama Canal,” according to Rep. Neugebauer, … Read More ›