UpFront » November 2022

The SEC’s Director of Enforcement, Gurbir Grewal, has publicly stated that firms should expect more sweeps with increasing frequency. The Enforcement Division’s plan seems to be backed up by the SEC’s record amount of fines collected during the past fiscal year, with prior sweeps a large contributor to that total. And now the SEC believes there is a need to push the pace of investigations even further given the volatility and uncertainty in the markets.…

Trying to determine what went wrong is central to unraveling a huge logjam of customer accounts awaiting required reviews at a large broker-dealer. The due diligence nightmare occurred at Morgan Stanley, where the accounts were closed or restricted pending further review. In exclusive comments, FrontLine’s Founder and President Amy Lynch points to a likely breakdown somewhere in the compliance chain, including a system wide automated process that did not have the necessary human intervention to…

Firms should prepare for an SEC that will take a hard look at their policies and practices for compliance with the newly effective Marketing Rule. Amy Lynch, FrontLine’s Founder and President, does not expect SEC targeted exams now being rolled out to give firms a lot of wiggle room to get their materials and policies in order. In the lead comments, Ms. Lynch also states that the SEC will most likely accumulate its findings from…

For the 9th 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 our remote compliance support services, our specialized forensic testing programs, and our services assisting hedge funds with the SEC’s new Marketing Rule and other anticipated new regulations for private funds. Also highlighted are FrontLine’s unmatched track record of client SEC exams resulting in…

When the SEC rescinded and then amended the Proxy Advisor Rule’s 2020 version, it claimed to follow a 30-day comment period that was procedurally valid. Now that process is being challenged in a lawsuit filed by advocacy groups, which state the SEC failed to thoroughly solicit and incorporate enough feedback during the comment period. Exclusively quoted, FrontLine’s Founder and President Amy Lynch explains that the 2022 version of the rule is deemed more investor-friendly as…