FrontLine Compliance has been monitoring the regulatory environment closely these past few weeks as our industry grapples with the COVID-19 (Coronavirus) outbreak. With the situation still unfolding here in the US, the regulators are trying to get a handle on the situation. The SEC, FINRA, and NFA have all issued guidance or information for the…
On January 27, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) released a report, Cybersecurity and Resiliency Observations (the “Report”), which outlines its examination findings over the past several years. OCIE has been reviewing cybersecurity practices at firms under its examination authority since 2012, conducting at least three specific targeted exams of investment advisers….
On January 7, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) released its 2020 Examination Priorities Report (the “Report”). The 2020 Report was released later than expected after the previous year’s early release in December 2018 (for the 2019 Report). It appears that the SEC is still playing “catch up” on its 2019 agenda,…
On November 7, 2019, the Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert (the “Alert”) on findings from fund examinations. The Alert covered findings from routine fund exams as well as recent targeted exams of money market funds (Money Market Fund Initiative) and target date funds (Target Date Fund Initiative). The data…
On September 4, 2019, the Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert (the “Alert”) on the results of examinations of investment advisers where issues regarding principal and agency cross transactions were discovered. The Alert described common deficiencies found generally, and at private fund firms, specifically. The findings discussed come from examinations…