Simons Says: Déjà Vu All Over Again, Version 2.0

Timothy M. Simons, CFA, CFP, CIPM, CSCP Senior Managing Member Focus 1 Associates LLC September 29, 2017   September 14, OCIE issued a Risk Alert On September 14, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk … Read More ›

Simons Says – The SEC and Cybersecurity

Timothy M. Simons, CFA, CFP, CIPM, CSCP Senior Managing Member Focus 1 Associates LLC August 23, 2017   January 9, 2014 – Examination Priorities for 2014 Although the SEC did refer to cybersecurity in the Examination Priorities for 2013, as … Read More ›

Simons Says: SEC Chairman Shares FY2018 Budget Request

Timothy M. Simons, CFA, CFP, CIPM, CSCP Senior Managing Member Focus 1 Associates LLC June 27, 2017   General Information On June 27, 2017, SEC Chairman Jay Clayton testified before the Senate Appropriations Subcommittee on the SEC’s Fiscal Year 2018 … Read More ›

Simons Says: Changing of the Guards

Timothy M. Simons, CFA, CFP, CIPM, CSCP Senior Managing Member Focus 1 Associates LLC December 28, 2016     Fiduciary Rules As the end of 2016 nears, I would like to spend a little time talking about the SEC’s Fiduciary … Read More ›

Simons Says: Changing Custody Guidance?

Timothy M. Simons, CFA, CFP, CIPM, CSCP Senior Managing Member Focus 1 Associates LLC September 26, 2016   I want to briefly discuss a topic about which questions have arisen in the last couple of months that we thought had been … Read More ›

Simons Says: Really? A Business Continuity Rule?

Timothy M. Simons, CFA, CFP, CIPM, CSCP Senior Managing Member Focus 1 Associates LLC June 29, 2016   On December 17, 2003, the SEC hit the investment adviser industry with the final rule for Compliance Programs of Investment Companies and … Read More ›