The Turning Tide: Has the SEC Finally Given CCOs the Credit They Deserve?

Jaqueline M. Hummel, Managing Director Hardin Compliance Consulting June 25, 2015 There have been three events in the last month to give compliance professionals hope. Ever since the passage of Advisers Act Rule 206(4)-7 (“the Compliance Program Rule”), the SEC has increasingly placed Chief Compliance Officers (“CCOs”) … 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 ›

Proposed Amendments to Form ADV

The SEC is proposing amendments to Form ADV that are designed to provide additional information regarding advisers, including information about their separately managed account  (SMA) business; incorporating a method for private fund adviser entities operating a single advisory business to … Read More ›