The ongoing SEC investigation; Amy Lynch discusses obligation to disclose (FundFire – Subscription Req’d)

An ongoing SEC investigation of an investment consultant that began in 2017 has raised questions on the timing of the firm’s disclosure to clients. In this particular case, as discussed in the article, information disclosed by the consultant to its clients has been inconsistent, with only some current clients being notified. Founder and President, Amy…

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ComplianceAlert

Exam Initiative Underway by OCIE

Last week, the Office of Compliance Inspections and Examinations (OCIE) announced new targeted exams of registered investment companies and advisers with specific types of investment activity. Specifically, exams will cover the following types of funds and activities: Index funds with custom indices Small ETFs and ETFs with limited trading volume Mutual funds investing in securitized…

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ComplianceAlert

OCIE Issues Risk Alert on Adviser Cash Solicitation Rule

The SEC, a sleeping giant for most of 2018, has suddenly awoken. It’s most recent activity has come in the form of a National Exam Program Risk Alert (“the Alert”). The Alert targets registered investment advisers and focuses on Rule 206(4)-3, the Cash Solicitation Rule (“the Rule”). SEC’s OCIE based its Alert on findings from its…

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FrontLine named to list of top hedge fund compliance experts for 5th consecutive year (Hedge Fund Alert – Subscription Req’d)

The recently released annual listing of compliance consultants again includes FrontLine Compliance as a leading firm offering compliance support and assistance to hedge funds. The listing highlights our successful track record of client SEC Exams resulting in no material findings, our 90 percent plus client renewal rate, and our team of seasoned compliance experts that…

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ComplianceAlert

SEC No-Action Letter Provides Relief for Fund Affiliated Transactions

On October 12, 2018, the SEC’s Division of Investment Management issued a no-action letter to the Independent Directors Council (“IDC”) regarding the oversight of affiliated transactions. Under the Investment Company Act, Rules 10f-3, 17a-7, and 17e-1 are commonly referred to in the fund industry as the “affiliated transaction rules” and are each an Exemptive Rule…

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