Proper disclosures rule for SEC; Amy Lynch on challenges with revenue sharing (IGNITES – Subscription Req’d)

The SEC continues to push firms to make amends for compliance failures related to their revenue sharing agreements. The latest point of emphasis coming out of the SEC is from its Division of Investment Management (IM) – it issued a FAQ describing its expectations for firm communications with clients about fee arrangements with third parties…

Read More

Amy Lynch Speaks on Books and Records Compliance at Annual Industry Event

Founder and President Amy Lynch will be a featured speaker at NSCP’s 2019 National Conference, October 21-23 in Baltimore, MD. On October 23rd, Ms. Lynch will offer her expertise as part of a two person panel discussing best practices for records management programs to ensure they are in compliance with investment adviser and investment company…

Read More

“Industry Pro” Amy Lynch’s comments on recent exams featured (Fund Intelligence – Subscription Req’d)

The SEC continues to revisit firms with prior deficiencies and is increasingly relying on its data analytics technology to determine its examination schedule. Founder and President Amy Lynch explains that the regulator has been returning to firms that had previous violations, conducting followup exams to ensure those firms have made the proper corrective measures. One…

Read More

ComplianceAlert

SEC Issues Alert on Affiliated Transactions

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…

Read More

Amy Lynch on revenue sharing cases and new SEC emphasis on disclosures (IGNITES – Subscription Req’d)

Recent SEC cases naming two prominent firms for violations related to their revenue sharing agreements could be a trend that continues through next year. FrontLine’s Founder and President Amy Lynch states that the recent cases are likely the first in a string that would likely include large, independent advisers, and not just distributors. Ms. Lynch further…

Read More