ComplianceAlert

NFA Updates Cybersecurity Components of Compliance Rule 2-9

On January 7, 2019, the NFA issued Notice I-19-01 to update its original interpretive notice regarding cybersecurity. The new amendment clarifies certain requirements for a CPO’s and CTA’s Information Systems Security Program (ISSP). Most firms adopted the original requirements in March 2016. Since then, the original NFA notice has been a best practice guide for…

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New firm registrations, among other items, now on hold at SEC; Amy Lynch comments (FundFire – Subscription Req’d)

The current government shutdown is having a wide-ranging impact on the ability for firms to interact with the SEC for registrations and fund launches, among other needs. According to Founder and President Amy Lynch, new firms that are trying to register with the SEC will face delays in that process. While many items that are…

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Amy Lynch discusses shutdown’s impact on SEC exams (InvestmentNews)

The current Federal government shutdown has essentially halted the SEC’s ability to complete ongoing exams or start new ones. Founder and President Amy Lynch explains that OCIE’s process during a shutdown is to suspend non-emergency or routine exams because they are not considered mission critical. Ms. Lynch further states that without funding for examiners’ travel,…

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ComplianceAlert

“Not Recently Examined” Firms a Focus for SEC in 2019

On December 20, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) released its 2019 Examination Priorities Letter (the “Letter”). The release came on the heels of a flurry of last minute activity by the SEC before both the holiday season and the impending government shutdown. OCIE was late to issue its 2018 exam priorities…

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ComplianceAlert

OCIE Offers Insight on E-Communications

The Office of Compliance Inspections and Examinations (OCIE) issued a new National Exam Program Risk Alert (the “Alert”) last week on electronic messaging. OCIE conducted an undisclosed number of limited scope examinations of investment advisers to determine the risks and controls surrounding the use of electronic messaging by advisers and their personnel. The examinations purposefully…

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