SEC, NASAA and FINRA Issue Senior Safe Act Fact Sheet to Help Promote Greater Reporting of Suspected Senior Financial Exploitation

On May 23, 2019 a fact sheet was released to help raise awareness on the immunity provisions of the Senior Safe Act which was passed one-year ago. The Act protects “covered financial institutions” defined as credit unions, depository institutions, investment … Read More ›

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Risk Alert: Safeguarding Customer Records and Information in Network Storage – Use of Third Party Security Features

Office of Compliance Inspections and Examinations (“OCIE”) On May 23, 2019 OCIE released a risk alert based on identified security risks associated with the storage of electronic customer records in various network storage solutions, including those leveraging cloud-based storage. The … Read More ›

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Risk Alert: Investment Adviser and Broker-Dealer Compliance Issues Related to Regulation S-P – Privacy Notices and Safeguard Policies

It’s time to review the Privacy Notice and policies and procedures surrounding Regulation S-P, including Safeguarding of Client Assets. On April 16, 2019, the Office of Compliance Inspections and Examinations, issued a Risk Alert describing compliance issues noted during examinations … Read More ›

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Focus Perspective: BDCs and CEFs

  The Securities and Exchange Commission (“SEC”) is proposing rules that would modify the registration, communications, and offering processes for business development companies (“BDCs”) and other closed-end investment companies (“CEFs”) under the Securities Act of 1933, as recently mandated by … Read More ›

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Focus Perspective: OCIE’s National Examination Program Risk Alert “Observations from Investment Adviser Examinations Relating to Electronic Messaging”

This Risk Alert (December 14, 2018) is to remind advisers of their obligations when they allow personnel to use electronic messaging, and to help advisers improve their systems, policies, and procedures by sharing the staff’s observations with regards to Rules … Read More ›

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Focus Perspective: What Does 2019 Bring

Kudos to the SEC.  Since 2013 when OCIE first identified its examination priorities for the upcoming year, they have been able to identify those priorities in the second fiscal quarter, but for 2019, OCIE identified those priorities on December 20, … Read More ›

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RIA Compliance Calendar – Filing Deadlines 2019

SEC Regulatory Deadlines for Investment Advisers The information provided in this calendar is intended to help compliance officers update their regulatory calendars for 2019.  It does not address all potential regulatory reporting and compliance obligations. Additionally, please note, this calendar … Read More ›

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Focus Perspective: Breaking Down OCIE’s 2019 Exam Priorities

On December 20, 2018, the SEC’s Office of Compliance Inspections and Examinations (OCIE), released its examination priorities for 2019. As we know, “OCIE is responsible for conducting examinations of entities registered with the SEC, including more than 13,200 investment advisers, … Read More ›

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SEC Office of Compliance Inspections and Examinations (“OCIE”) Announces 2019 Examination Priorities

Each year OCIE publishes its exam priorities to promote transparency of its examination program which oversees investment advisers, mutual funds and exchange traded funds, broker-dealers, transfer agents, clearing agencies, national securities exchanges, municipal advisors, FINRA, MSRB, SIPC and PCAOB. This … Read More ›

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Risk Alert: Observations from Investment Adviser Examinations Relating to Electronic Messaging

The SEC released a Risk Alert to remind advisers of their obligations when their personnel use electronic messaging, and to help advisers improve their systems, policies, and procedures. The alert identifies examples of practices that the staff believes may assist … Read More ›

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