Trend of more transparency by investment consultants continues; Amy Lynch comments (FundFire – Subscription Req’d)

Recent new material updates on its Form ADV by an investment consultant indicate that it will separately charge clients for providing fee negotiation services. The service seeks to secure more favorable fund fee terms for clients. Founder and President Amy Lynch explains that consultants have been expanding their product offerings and service levels, but at…

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ComplianceAlert

Summary of SEC’s Outreach Seminar

On April 12, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) hosted its annual Compliance Outreach Program National Seminar for Investment Adviser and Investment Company Senior Officers (the “Seminar”). The annual Seminar is held at OCIE headquarters in Washington, DC and is attended by a limited number of industry representatives, each approved by SEC…

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ComplianceAlert

IM Issues New Guidance on Adviser Custody

The SEC’s Division of Investment Management (IM) just issued new guidance on the Custody Rule 206(4)-2. Most likely this new guidance is a result of the special custody exams conducted by OCIE in 2016. It appears that the examination Staff observed several instances of inadvertent custody via special arrangements between advisory clients and client custodians….

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In the Matter of…Compliance Consultants

There has been some talk lately about a particular investment adviser legal proceeding called In the Matter of The Robare Group, LTD., Mark L. Robare, and Jack L. Jones, Jr.   Law firms have promoted this case to argue their point that firms should only hire licensed legal counsel to assist with compliance matters or at…

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ComplianceAlert

IM Issues New Guidance on Form PF

The SEC’s Division of Investment Management (IM) updated the Form PF FAQ available on the SEC website. The updates are intended to provide guidance for firms filing their annual or quarterly updates in the coming months. IA Release No. 3879 (note the release number stated in the IM Update is incorrect) on money market fund…

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