News & Analysis as of

Investment Management Internal Controls

The Volkov Law Group

SEC Risk Alert on ESG Investing

The Volkov Law Group on

I have written extensively about the new and hot business trend – environmental, social and governance programs (“ESG”).  The luster surrounding ESG has been a significant business trend and priority. Like any new trend, the...more

Morgan Lewis

The SEC Staff Takes On ESG Investing

Morgan Lewis on

In the US Securities and Exchange Commission staff’s most recent guidance addressing environmental, social, and governance (ESG) investing, the staff of the Division of Examinations released an April 9 Risk Alert noting...more

Proskauer Rose LLP

Regulation of Custodial Practices Under the Investment Advisers Act of 1940 Rule 206(4)-2: September 2020

Proskauer Rose LLP on

A. Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...more

Hogan Lovells

U.S. Sanctions regulator outlines expectations for Global Sanctions Compliance: impact on Private Equity

Hogan Lovells on

On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more

Proskauer Rose LLP

UK Financial Conduct Authority Identifies Significant Shortcomings in Firms Operating Appointed Representative Platforms

Proskauer Rose LLP on

On 20 May 2019, the UK Financial Conduct Authority ("FCA") published its findings of its multi-firm review into the supervision by principal firms of their appointed representatives ("ARs") operating in the investment...more

Akin Gump Strauss Hauer & Feld LLP

NFA Issues Interpretive Notices for CPOs Regarding Internal Controls Systems and Cybersecurity

• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more

Morgan Lewis

NFA Issues Internal Controls Guidance for Commodity Pool Operators

Morgan Lewis on

The National Futures Association (NFA) recently proposed an interpretive notice that would require members that are commodity pool operators (CPOs) to adopt and implement internal controls systems designed to deter fraudulent...more

Dorsey & Whitney LLP

Recent Enforcement Provides Guidance on Internal Controls and Disclosure for Quant Managers

Dorsey & Whitney LLP on

The recent enforcement action by the Securities and Exchange Commission (“SEC”) against Aegon USA Investment Management (“AUIM”) and three affiliated companies provides helpful guidance to investment advisers who employ...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Bureau of Consumer Financial Protection Issues Policy on No-Action Letters - On February 18, the Consumer Financial Protection Bureau issued a new policy statement on No-Action Letters. Under the Policy, Bureau...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

Troutman Pepper on

1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

10 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide