On January 27, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) released a report, Cybersecurity and Resiliency Observations (the “Report”), which outlines its examination findings over the past several years. OCIE has been reviewing cybersecurity practices at firms under its examination authority since 2012, conducting at least three specific targeted exams of investment advisers….
Both FINRA and the SEC are looking into potential violations committed by firms that utilize cash-sweep programs and whether proper disclosures are being made to their customers. Amy Lynch, FrontLine’s Founder and President, advises that firms now grappling with Regulation Best Interest may also want to review the disclosure requirements relevant to conflicts of interest…
Last week the SEC released FAQs on Reg BI, the central part of the new regulations passed by the SEC that intend to offer more protections to retail investors. Reg BI and its related Form CRS, the customer relationship disclosure document, are required to be implemented by June 30th of this year. Founder and President Amy Lynch…
The recent release of the SEC’s 2020 exam priorities has put firms with ESG investment strategies on notice. This next year, as one of its exam priorities, OCIE plans to focus on the disclosures provided by these firms to their clients. Amy Lynch, Founder and President, comments that the SEC is taking note of the proliferation of firms…
On January 7, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) released its 2020 Examination Priorities Report (the “Report”). The 2020 Report was released later than expected after the previous year’s early release in December 2018 (for the 2019 Report). It appears that the SEC is still playing “catch up” on its 2019 agenda,…