Advisers

FYI: Most Frequent Adviser Advertising Compliance Issues

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FYI: OCIE issued a Risk Alert today containing the most frequently identified advertising compliance issues reflected in deficiency letters from over 1,000 adviser exams and observed as part of OCIE’s “Touting Initiative,” nearly 70 adviser exams conducted in 2016 that focused on advisers’ use of accolades in their marketing materials. While it is sometimes helpful when OCIE identifies “top” compliance issues found on exams, this Risk Alert reads more like a catalog of the most difficult issues that advisers face in the advertising arena, along with one or two citations to previously issued cases or guidance to illustrate each topic. […]

Advisers

FYI: 2017 Investment Management Compliance Survey

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FYI: The IAA has released its report on the 2017 Investment Management Compliance Survey. This year’s survey areas included: • Remote/Branch Office Supervision • Use of Automation • Fees and Expenses • Wrap Programs • Whistleblowing • Business Continuity and Transition Planning • Impending Regulations: Form ADV Part 1A and Liquidity Risk Management, and • International Regulation (MiFID II). Key findings included, among others: • Cybersecurity continues to be the hottest compliance topic in 2017 for the 4th year in a row. • Other hot topics included custody, regulatory reporting and disaster recovery planning. • Only about 21% of firms […]

Advisers

FYI: SEC Personnel Changes

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FYI: Dalia Blass has been named Director of the SEC’s Division of Investment Management. Although she is returning to the SEC from the private sector, she has more than a decade of prior experience in the Division of Investment Management, include serving as Assistant Chief Counsel. Blass announcement: https://www.sec.gov/news/press-release/2017-153 Nominations have also been made to fill the open seats on the Commission. Former congressional aide Hester Peirce has been nominated to fill the open Republican seat. Columbia University law professor Robert Jackson has been nominated to fill the open Democratic seat. If these nominees are confirmed by the Senate, the […]