ComplianceAlert

Fee and Expense Allocation Deficiencies Uncovered

The Division of Examinations (the “Division”) conducted exams of 130 retail advisers where the Staff reviewed fee and expense billing practices. Its latest Risk Alert (the “Alert”) details the results of these exams and is structured similarly to others released in 2021, whereby the Staff describes both deficiencies found as well as best practices. Of note, the Alert is a second consecutive one issued during the same week and exemplifies just how active the Exam…

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Personal trading policies vary on crypto investing (IGNITES)

For the most part, firm personal trading policies for employees investing in crypto-related investments appear to be following standard policies on requiring disclosure of transactions that are considered “reportable securities.” But in the age of crypto and coin offerings, firms are having to deal with murky definitions when it comes to what employees need to disclose. Amy Lynch, FrontLine’s Founder and President, explains that coins and other digital assets could be considered covered securities since…

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SEC exams on the rise under Gensler (Hedge Fund Alert)

Industry regulatory experts report that the frequency of SEC exams has been steadily increasing under its Chairman Gary Gensler. However, more recently and within the last two months, a noticeable surge in the number of exams seems to have occurred, comments FrontLine Compliance Founder and President Amy Lynch. This may be attributed to the time saving achieved by the SEC not traveling to firms’ offices combined with Gensler’s aggressive agenda now getting off the ground.…

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ComplianceAlert

Division of Investment Management Update on New Marketing Rule

The SEC’s Division of Investment Management (IM) recently issued an Information Update on the new Marketing Rule, amended Rule 206(4)-1. Significantly, the update includes a list of the SEC no-action letters (“Staff Letters”) that are now withdrawn and no longer valid for reliance by investment advisers. This is the result of the modifications to the Advertising Rule and Cash Solicitation Rule, which occurred at the end of last year. The new rule has a full…

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FrontLine is once again named a top hedge fund compliance firm (Hedge Fund Alert)

For the 8th consecutive year, the recently released annual listing of compliance consultants includes FrontLine Compliance as a leading firm offering compliance support and advising to hedge funds. The select listing features the growth of our remote compliance support services, our specialized forensic testing programs and our unmatched track record of client SEC exams resulting in no material findings. Also highlighted is FrontLine’s 90 percent plus client renewal rate and our team of top compliance…

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