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…

Advertising and Marketing Regulation | Best Execution | Code of Ethics | Compliance Program Rule, Rule 206(4)-7 | Compliance Programs | Custody | Disclosures | Examinations and Audits | Form ADV


The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) is upfront about the areas it will be testing during its examinations of investment advisers.  In January, OCIE publishes its Examination…