Despite the prospect for federal policy gridlock with a divided Congress, the financial markets may be where a Biden administration has the greatest influence. Expect stricter enforcement and more aggressive regulation with a new SEC Chair, even with a revealing number of actions and penalties under the current SEC. Amy Lynch, FrontLine’s Founder and President,…
On November 19, 2020, the Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert (the “Alert”) on observed deficiencies related to Rule 206(4)-7 (the “Compliance Rule”). In the Alert, OCIE cites notable deficiencies or weaknesses culled from a sample of deficiency letters following recent investment adviser exams. Compliance Rule deficiencies have been among…
SEC Chairman Jay Clayton’s year-end departure will expedite the Biden administration’s plans to have a new SEC chair in place earlier in 2021. Lead comments by FrontLine’s Founder and President, Amy Lynch, recommend that firms tighten up their compliance before a strengthened SEC with a larger enforcement mandate gains traction. Where the focus has been…
Valuation policies should help guide a process to meet SEC requirements, but in certain situations that could become challenging. For hedge funds and other private funds, certain steps can help avoid potential violations when firm guidelines do not include a failsafe in instances that require a deviation from the usual valuation procedures. Amy Lynch, FrontLine’s…
When the SEC transitions to an agency with a Democratic majority, it’s priorities will most certainly shift. Look for greater emphasis on ESG issues – including a possible ESG disclosures rule proposal – and revisiting regulations on proxy voting, as well as components of Regulation Best Interest. FrontLine’s Founder and President, Amy Lynch, believes a…