ComplianceAlert

New SEC Exam Initiative – Whistleblower Rule Compliance

The SEC issued a National Exam Program (NEP) Risk Alert on Monday, October 24th to put investment advisers and broker-dealer registrants on notice that OCIE examiners are looking into how firms comply with Rule 21F-17 of the Dodd-Frank Act, otherwise known as the the “Whistleblower Rule.” Examination staff are concerned that registrants are limiting the…

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ComplianceAlert

New SEC Requirements for Form ADV and Recordkeeping

The SEC kicked off September by finalizing its Form ADV and adviser recordkeeping changes. IA Release No. IA-4509 was issued on September 1, 2016 with an effective date of October 31, 2016. Compliance with the new requirements will be required for all SEC registered advisers as of October 1, 2017. The Form ADV changes add…

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ComplianceAlert

Regulator Weighs in on CCO Supervision

In July, the CFTC issued a Staff Advisory on Chief Compliance Officer (CCO) Reporting Lines. The letter was addressed to swap dealers, major swap participants, and future commission merchants. However, the major points of this letter ring true for any regulated entity with a CCO. The Commodity Exchange Act (CEA) regulations regarding the role of…

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A Message from the President

Well, the Boardroom has been empty now for too long so it’s time to get back in session. This meeting is officially called to order by Amy Lynch. There is a true story that I don’t tell often enough. It’s the story of how my compliance career began over 20 years ago… In the mid…

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ComplianceAlert

FAQ on SEC’s New Share Class Exams

In July, the SEC’s National Exam Program issued a Risk Alert regarding its new 2016 Share Class Initiative, which has already begun. The following is an FAQ that addresses what you need to know now in order to prepare for a Share Class exam: What types of firms will the SEC visit? A. SEC registered…

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