Recent SEC Enforcement actions on advertising violations demonstrate that investment advisers increasing reliance on social media continues to pose challenges. With social media now a staple of marketing for advisers, Amy Lynch comments that these firms must review numerous, and sometimes decades old, SEC public statements – forums, speeches, no-action letters and enforcement proceedings – to determine compliance on social media usage. Lynch further adds that firms should have training and written policies and procedures…
On July 11, 2018, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (“Risk Alert”) that summarizes its findings from over 1,500 investment adviser examinations. Best execution analysis and monitoring has long been a challenge for investment advisers due to the lack of control over the execution process itself. Broker-dealers conduct trade execution, not the investment adviser, so access to execution data may be difficult to obtain,
Despite…
On June 28, 2018, the SEC updated its Investment Company Liquidity Disclosure Rule via SEC Release No. IC-33142. The updates clarify and simplify certain required reporting by funds to the SEC. Surprisingly, the revisions come well before the earliest compliance dates for funds – December 1, 2018 – under the new Liquidity Risk Disclosure Rules.
The Commission received several letters from industry participants that pushed back on certain aspects of the new rule. Specifically, the…
ROCKVILLE, MD (July 10, 2018) — FrontLine Compliance, LLC has further strengthened its consulting team in response to the continued growth of the firm’s offerings of regulatory compliance advising and support for SEC registered investment advisers and private funds. Mike Spero, a former Chief Compliance Officer, recently joined FrontLine Compliance as Senior Vice President to handle clients’ compliance requirements.
Mr. Spero specializes in complex regulatory compliance matters for investment advisers and private funds. With over…
