ComplianceAlert

IM Issues New Guidance on Adviser Custody

The SEC’s Division of Investment Management (IM) just issued new guidance on the Custody Rule 206(4)-2. Most likely this new guidance is a result of the special custody exams conducted by OCIE in 2016. It appears that the examination Staff observed several instances of inadvertent custody via special arrangements between advisory clients and client custodians….

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ComplianceAlert

SEC Offers Rare Examination Insight

This week the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued its overview of investment adviser examination findings since February 2015. The Risk Alert is a rare disclosure of OCIE examination findings. Five of the most common examination deficiencies are discussed in the Alert. Violations to hit the top five (5) list are as…

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ComplianceAlert

IM Issues New Guidance on Form PF

The SEC’s Division of Investment Management (IM) updated the Form PF FAQ available on the SEC website. The updates are intended to provide guidance for firms filing their annual or quarterly updates in the coming months. IA Release No. 3879 (note the release number stated in the IM Update is incorrect) on money market fund…

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ComplianceAlert

New SEC Exam Initiative – Whistleblower Rule Compliance

The SEC issued a National Exam Program (NEP) Risk Alert on Monday, October 24th to put investment advisers and broker-dealer registrants on notice that OCIE examiners are looking into how firms comply with Rule 21F-17 of the Dodd-Frank Act, otherwise known as the the “Whistleblower Rule.” Examination staff are concerned that registrants are limiting the…

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ComplianceAlert

New SEC Requirements for Form ADV and Recordkeeping

The SEC kicked off September by finalizing its Form ADV and adviser recordkeeping changes. IA Release No. IA-4509 was issued on September 1, 2016 with an effective date of October 31, 2016. Compliance with the new requirements will be required for all SEC registered advisers as of October 1, 2017. The Form ADV changes add…

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