The SEC wants to review and update its advertising and solicitation rules to give them a refresh for today’s innovation and technological advances. According to FrontLine Compliance President Amy Lynch, the SEC should tackle three important issues that need greater clarity: presentation of performance data, social media marketing and online solicitations. Ms. Lynch further comments that in the current digital age, compliance officers must piece together interpretations from various no-action letters since the rules are…
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A recent risk alert issued by the SEC indicates that the regulator has a renewed focus on how advisers are charging their clients. In the alert, the SEC cited a number of deficiencies related to fees that were uncovered during exams. Founder and President Amy Lynch states that firms should be on notice that the SEC is looking closely at advisers’ fee practices and how they are charging clients. Ms. Lynch notes that various types…
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ComplianceAlert
On April 12, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) hosted its annual Compliance Outreach Program National Seminar for Investment Adviser and Investment Company Senior Officers (the “Seminar”). The annual Seminar is held at OCIE headquarters in Washington, DC and is attended by a limited number of industry representatives, each approved by SEC staff. The Seminar is also broadcast live via webcast for those unable to attend in person.
This year the Seminar…
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ComplianceAlert
Today the Office of Compliance Inspections and Examinations (OCIE) issued another National Exam Program Risk Alert (the “Alert”). The Alert focused on the findings from 1,500 adviser examinations conducted over the past two years. Of concern from those examinations, OCIE staff found that many firms failed in some way regarding the application or disclosure of advisory fees and expenses.
In summary, the Alert highlighted the following exam findings regarding fees and expenses:
Fees based upon…
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The SEC and money manager clients have raised the bar for investment consultants to provide greater transparency, especially as it relates to their compensation that could create conflicts of interest and prevent impartiality. Founder and President Amy Lynch sees consultants now adding more language to their ADVs about their gifting policies. She notes that adding clear language and including more details on fees and conflicts would be a good idea considering the pressure now on…
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