Category: Conflicts of Interest
Annual Compliance Program Review | Blue Sky Filings | Broker Dealer | Compliance Program Rule, Rule 206(4)-7 | Compliance Programs | Conflicts of Interest | Cybersecurity | Disclosures | Examinations and Audits | Form ADV | Investment Advisers | Mutual Funds | SEC Risk Alert | Seniors and Vulnerable Investors | States | Supervision
SEC’s Top Eleven Hits: Investment Adviser Regulatory Review 2019
In addition to basic blocking and tackling, compliance officers often have the thankless job of performing the annual review of their compliance program required by Advisers Act Rule 206(4)-7. As…
Best Execution | Code of Conduct | Conflicts of Interest | Disclosures | Examinations and Audits | Fiduciary
What Your Next Deficiency Letter is Going to Say: SEC Tells Advisers What Fiduciary Duty Means
With all the buzz about the passage of Regulation Best Interest (“Reg BI”), the “Commission Interpretation Regarding Standard of Conduct for Investment Advisers” (the “Interpretation”) has received much less attention….
Best Execution | Cash Solicitation Rule | Compliance Programs | Conflicts of Interest | Cybersecurity | Examinations and Audits | Investment Advisers Act | Investment Company Act | Liquidity | Mutual Funds | Private Investment Funds | Share Class Selection Disclosure | Testing
Eleven Key Takeaways for Updating your Compliance Program in 2019: Investment Advisers, Mutual Funds, Hedge Funds and Private Equity Funds
Photo by NordWood Themes on Unsplash Cari Hopfensperger, Senior Compliance Consultant, co-wrote this article. Based on regulatory developments from 2018, here are our suggestions for updates to your compliance program for 2019. Conflict…
Best Execution | Cash Solicitation Rule | Chief Compliance Officer | Compliance Programs | Conflicts of Interest | Custody | Cybersecurity | Disclosures | Examinations and Audits | Mutual Funds | Private Equity Funds
SEC’s Top Eleven Hits: Investment Adviser Regulatory Review 2018
Photo by Mark Duffel on Unsplash The SEC’s regulatory actions in 2018 involved few surprises but still managed to challenge investment advisers. In reviewing the SEC’s activity over the past 12 months, I…
Best Execution | Conflicts of Interest | Mutual Funds
Why the SEC is Obsessed with Mutual Fund Share Class Selection and Disclosure (and why you should be too)
On April 6, 2018, the SEC released three settlement orders with investment advisers because they “failed to disclose conflicts of interest and violated their duty to seek best execution by…
Best Execution | Conflicts of Interest | Disclosures | Mutual Funds | SEC News
SEC Offers “Favorable Terms” to Advisers that Self-Report Failure to Disclose Receipt of 12b-1 Fees
On February 12, 2018, the SEC Division of Enforcement announced a new self-reporting initiative – the Share Class Selection Disclosure (the “SCSD Initiative”). The Initiative, led by the Commission’s Asset…
Conflicts of Interest | Disclosures | Form ADV
SEC Imposes Strict Liability Standard on Advisers, Dismissing Due Care Defense
The first week of November was a time for surprises, but most surprising to me was the SEC’s decision in In re The Robare Group, Ltd. Back in 2015, I…
Conflicts of Interest | Department of Labor | DOL Fiduciary Rule | ERISA | Fiduciary
Q and A from Webinar on DOL’s New Fiduciary Rule
Questions & Answers from Webinar on: DOL Conflicts of Interest Rule Impact on Investment Advisers June 15, 2016 Does BICE apply when an adviser has a mutual fund and the…
Code of Conduct | Code of Ethics | Conflicts of Interest | Ethics
Trust but Verify: The SEC Addresses “Control” under Code of Ethics Rule
By: Jaqueline M. Hummel, IACCP®, AIFA® Managing Director Hardin Compliance Consulting LLC The SEC recently came out with guidance under Rule 204A-1 of the Advisers Act, which requires registered investment…
Compliance Program Rule, Rule 206(4)-7 | Compliance Programs | Conflicts of Interest | Examinations and Audits | Investment Advisers Act
Just in time for Halloween: Compliance Rule Horror Stories (Part 3 of a 3-part series)
October 30, 2014 Jaqueline M. Hummel Managing Director, Hardin Compliance Consulting, LLC In this final installment of a three-part series, the most recent cases involving violations of the Compliance Program…