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 Significantly, the update includes a list of the SEC no-action letters (“Staff Letters”) that are now withdrawn and no longer valid for reliance by investment advisers.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…

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ComplianceAlert

SEC Risk Alert Issued on Fund Exam Findings

The SEC’s Division of Examinations (formerly known as OCIE) has issued a new Risk Alert (the “Alert”) on findings from fund examinations over the past few years. The Alert covers examination weaknesses and best practices discovered from the Division’s inspections of over 50 fund complexes, 200 funds and close to 100 advisers since late 2018….

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ComplianceAlert

SEC Risk Alert Issued on Prohibited Transactions

The SEC’s Division of Examinations (formerly known as OCIE) has issued a new Risk Alert (the “Alert”) on principal and cross trades for fixed income managers. More than 20 fixed income managers were examined as part of a special study on prohibited transactions (FIX Initiative) that began more than two years ago. The investment advisers…

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ComplianceAlert

SEC Releases New Rules Agenda

The SEC has released an updated rulemaking agenda for this year. New Chairman Gary Gensler has been in office a few months now and is beginning to put his stamp on the Commission. As part of that, the rulemaking agenda has been updated to address recent concerns of the SEC. The new list of rules…

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ComplianceAlert

SEC Tackles ESG Investing and Compliance

The SEC’s Division of Examinations (EXAMS) issued a key Risk Alert (the “Alert”) that tackles the thorny compliance issues surrounding ESG (Environmental, Social, and Governance) investment themes. EXAMS has conducted reviews of RIAs and funds that follow ESG strategies and compiled a list of both positive and negative findings from those examinations. RICS (Registered Investment…

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