News & Analysis as of

Office of Compliance Inspections and Examinations

Expect Focus - Life Insurance, Volume III - September 2017

by Carlton Fields on

EXPECTFOCUS® is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. Please see full Publication...more

Expect Focus - Life Insurance, Volume III - September 2017

by Carlton Fields on

EXPECTFOCUS® is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. Please see full Publication...more

OCIE Publishes Risk Alert on Most Frequent Advertising Rule Compliance Issues Found During Examinations

by Dechert LLP on

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued a National Exam Program Risk Alert on September 14, 2017 (Risk Alert). The Risk Alert highlights...more

Regulatory Update and Recent SEC Enforcement Actions

by Blank Rome LLP on

Investment Firm VanEck Launches Bitcoin Exchange Traded Fund (“ETF”) One Week after Calling Bitcoin a “Fad” - On August 10, 2017, Joe Foster, portfolio manager and strategist for the money management firm VanEck, expressed...more

SEC Scrutinizes Multi-Manager Arrangements

by Carlton Fields on

Many mutual funds implement their investment strategies through "multi-manager" (also called "manager of manager") arrangements, particularly funds used to support variable life insurance and annuity products. Among other...more

OCIE Lessons From Cybersecurity 2 Initiative

by Carlton Fields on

On August 7, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert containing observations from its Cybersecurity 2 Exam Initiative. As a follow-up to the 2014 Cybersecurity 1 initiative, the...more

Bridging the Week - September 2017 #2

SEC Begins Proactively Suggesting Some Promoters Halt ICOs; the UK Financial Conduct Authority Joins Worldwide Regulators Saying that Digital Tokens Issued as Part of ICOs May Be Securities: Following the release of the...more

Funds Talk: October 2017 - SEC Report Highlights Financial Firms’ Cybersecurity Improvements and Shortcomings

On Aug. 7, 2017, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert summarizing the results of its second cybersecurity preparedness examination. ...more

OCIE Releases Risk Alert Regarding Advertisements of Investment Advisers

by Bracewell LLP on

On September 14, 2017, OCIE published a Risk Alert identifying issues associated with Rule 206(4)(1) of the Investment Advisers Act of 1940 (the “Advertising Rule”). The Risk Alert was based on observations of the OCIE staff...more

Funds Talk: October 2017 - SEC Issues Risk Alert Regarding Advertising Rule Compliance Based on Recent OCIE Examinations

On Sept. 14, 2017, the Securities and Exchange Commission (the “SEC”) issued a risk alert outlining certain compliance issues identified by the regulator’s Office of Compliance Inspections and Examinations (“OCIE”) related to...more

The SEC’s Office of Compliance Inspections and Examinations Warns Investment Advisers: “Don’t Mislead or We Will Proceed!”

On September 14, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert in which it highlighted a number of compliance issues it had identified relating to the so-called Advertising...more

Legal Advice Not Enough for Adviser to Avoid SEC Sanctions

by Dorsey & Whitney LLP on

Undisclosed conflicts of interest have been a key focus of OCIE exams of investment advisers. Those undisclosed conflicts have resulted in a series of enforcement actions against advisers. ...more

SEC Issues Risk Alert on the Most Frequent Advertising Rule Compliance Issues and Use of Accolades in Advertisements

by Proskauer Rose LLP on

I. Advertising Rule Compliance Issues - On September 14, 2017, the staff of the SEC's Office of Compliance Inspections and Examinations (OCIE) issued a National Examination Program Risk Alert on the most frequent advertising...more

Financial Services Weekly News - September 2017 #2

by Goodwin on

Editor's Note - In This Issue. Federal banking agencies are seeking public comment on their proposed revisions to the Community Reinvestment Act (CRA), the Consumer Financial Protection Bureau (CFPB) released a small...more

SEC Wants the Truth and Nothing but the Truth in Advertising

Tell the truth, the whole truth, and nothing but the truth: that’s the message to registered investment advisors from the Office of Compliance Inspections and Examinations (OCIE) in a recent risk alert about the SEC’s...more

SEC Issues Guidance on Investment Adviser Advertising Rule

by Dorsey & Whitney LLP on

On September 14, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a new Risk Alert outlining the most frequent compliance issues relating to Rule 206(4)-1 (the “Advertising Rule”) under the...more

SEC Office of Compliance Inspections and Examinations Announces Most Frequent Advertising Rule Compliance Issues for 2017

by Locke Lord LLP on

The Office of Compliance Inspections and Examinations (the “OCIE”) published a Risk Alert on September 14, 2017 discussing the most frequent issues that the OCIE observed during its examinations of investment advisers with...more

OCIE Spots Issues and Alerts Registered Advisers on Most Frequent Advertising Compliance Problems

On September 14, 2017, the National Exam Program of the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert outlining registered investment adviser compliance issues relating to Rule...more

SEC Identifies Most Frequent Compliance Issues Associated with Advertising by Investment Advisers

The SEC’s Office of Compliance Inspections and Examinations has provided a list of compliance issues relating to Rule 206(4)-1, which is referred to as the Advertising Rule, under the Investment Advisers Act of 1940. In...more

OCIE Releases Cybersecurity Risk Alert

by Bracewell LLP on

On August 7, 2017, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a Risk Alert summarizing its most recent cybersecurity examination findings. As a part of its Phase...more

OCIE Releases Results of Cybersecurity Examination Initiative

On August 7, 2017, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a summary of its observations (the report) from cybersecurity examinations of 75...more

Investment Services Regulatory Update - August 2017

by Vedder Price on

On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert providing a summary of the staff’s observations from sweep exams of broker-dealers, investment advisers and funds...more

SEC Publishes Cybersecurity Risk Alert

by Balch & Bingham LLP on

On August 7 2017, the U.S. Securities and Exchange Commission (SEC), through its Office of Compliance Inspections and Examinations (OCIE), published a Risk Alert summarizing observations on how broker dealers, investment...more

Analysis: Cyber-Monitoring: The Next Frontier

by Dickinson Wright on

Cybersecurity is “hot” and will stay “hot” for corporations, executives, regulators, law enforcement and legislators. Rarely is there a corporate compliance discussion in 2017 where cyber isn’t “the” topic or a material part...more

The Good and the Bad from OCIE’s Cyber Examinations and What Firms Should Do Next

by Dechert LLP on

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a National Examination Program Risk Alert (Risk Alert) on August 7, 2017 regarding observations from...more

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Cybersecurity

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