ComplianceAlert

SEC Revises Fund Liquidity Risk Management Protocols

On June 28, 2018, the SEC updated its Investment Company Liquidity Disclosure Rule via SEC Release No. IC-33142. The updates clarify and simplify certain required reporting by funds to the SEC. Surprisingly, the revisions come well before the earliest compliance dates for funds – December 1, 2018 – under the new Liquidity Risk Disclosure Rules….

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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

SEC Issues Alert on Advisory Fees and Expenses

Today the Office of Compliance Inspections and Examinations (OCIE) issued another National Exam Program Risk Alert (the “Alert”). The Alert focused on the findings from 1,500 adviser examinations conducted over the past two years. Of concern from those examinations, OCIE staff found that many firms failed in some way regarding the application or disclosure of…

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ComplianceAlert

SEC Issues its 2018 Exam Priorities

On February 7, 2018, the Office of Compliance Inspections and Examinations (OCIE) issued its much awaited 2018 National Exam Program Examination Priorities. What was issued this year reads more like a business plan or mission statement for the SEC rather than a letter to the industry, as has been the style in years past. However,…

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ComplianceAlert

SEC Seeks Response from Industry on Cryptocurrency Funds

On January 18, 2018, the Director of the Division of Investment Management, Dalia Blass, issued a Staff Letter to the Investment Company Institute (ICI) and the Securities Industry and Financial Markets Association (SIFMA) regarding the use of cryptocurrency mutual funds and ETFs. The letter requests comments from both the ICI and SIFMA, as well as…

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