Category: Conflicts of Interest
Broker Dealer | Compliance Programs | Conflicts of Interest | COVID-19 | Cybersecurity | FINRA | Form CRS | Regulation Best Interest
Broker-Dealer – 2020 Regulatory Year in Review
2020 was a difficult year for broker-dealers as they found themselves not only juggling their regular day-to-day obligations, the implementation of Form CRS and Regulation Best Interest policies and procedures,…
Conflicts of Interest | Form ADV | Investment Advisers | Share Class Selection Disclosure
Coming Clean on Conflicts of Interest: Tips for Updating Your Form ADV for 2020
As you prepare your update to Form ADV, pay particular attention to disclosure of conflicts of interest. Everyone should have gotten the memo by now about disclosure of 12b-1 fees…
Annual Compliance Program Review | Compliance Programs | Conflicts of Interest | Cybersecurity | Disclosures | Investment Advisers | Seniors and Vulnerable Investors
SEC’s Top 10 Hits: Investment Adviser Regulatory Review 2019 – Part 2
Here the remaining top 5 hits from our investment adviser regulatory review. (Check out Part 1 here.) The SEC remains concerned about information security, including cyber-related risks, and 2020 is…
Annual Compliance Program Review | Compliance Programs | Conflicts of Interest | Cybersecurity | Disclosures | Investment Advisers | Seniors and Vulnerable Investors
SEC’s Top 10 Hits: Investment Adviser Regulatory Review 2019 – Part 1
Based on regulatory developments from 2019, here are our suggestions for updates to your RIA compliance program for 2020. The SEC’s top regulatory initiatives in 2019 defined the standard of…
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…