In the Matter of…Compliance Consultants

There has been some talk lately about a particular investment adviser legal proceeding called In the Matter of The Robare Group, LTD., Mark L. Robare, and Jack L. Jones, Jr.   Law firms have promoted this case to argue their point that firms should only hire licensed legal counsel to assist with compliance matters or at the very least, hire a compliance consultant via counsel to protect “the reliance on counsel” defense for enforcement actions. The…

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IM Issues New Guidance on Form PF

The SEC’s Division of Investment Management (IM) updated the Form PF FAQ available on the SEC website. The updates are intended to provide guidance for firms filing their annual or quarterly updates in the coming months. IA Release No. 3879 (note the release number stated in the IM Update is incorrect) on money market fund reforms facilitated the need for certain revisions due to the new requirements for unregistered liquidity funds. Listed below is a…

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