The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) highlighted alternative data, or “alt data,” as a top examination priority. AIMA held a webinar on November 17, 2020, for...more
12/16/2020
/ AIMA ,
Breach of Contract ,
Compliance ,
Data Mining ,
Due Diligence ,
Employee Training ,
Infringement ,
Investment Advisers Act of 1940 ,
MNPI ,
OCIE ,
Securities and Exchange Commission (SEC) ,
Web Scraping
The Office of Compliance Inspections and Examinations (OCIE) issued a risk alert on November 19, 2020 related to the Advisers Act compliance rule, Rule 206(4)-7. Some key takeaways for Chief Compliance Officers (CCOs) are as...more
SEC Speaks, the annual PLI conference that gives practitioners the chance to hear directly from SEC Staff, was held on October 8 and 9 in a virtual setting. While the conference (like everything else) felt a bit different...more
Non-Enforcement -
FINRA’s Proposed Pay-to-Play Rule Will Impact Investment Advisers -
Late last year (December 24, 2015), the Financial Industry Regulatory Authority (FINRA) submitted a proposed rule to the U.S....more
2/3/2016
/ 12b-1 plan ,
Cybersecurity ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Fund Managers ,
Investment Adviser ,
Investor Protection ,
OCIE ,
Pay-To-Play ,
Sanctions ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Transparency
Non-Enforcement -
A Source of Concern for the SEC — The Outsourcing by Investment Advisers and Funds of Compliance Activities -
In a recent National Exam Program Risk Alert (dated November 9, 2015) the U.S....more
Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more
10/1/2015
/ Blue Sky Laws ,
Board of Directors ,
Broker-Dealer ,
Chief Compliance Officers ,
Civil Monetary Penalty ,
Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Derivatives ,
Disclosure Requirements ,
ETFs ,
Free Identity Theft Protection ,
Hackers ,
Investment Portfolios ,
Liquidity Risk Management Rule ,
Mutual Funds ,
NAV ,
New Guidance ,
OCIE ,
Personally Identifiable Information ,
Policies and Procedures ,
Proposed Regulation ,
Registered Investment Advisors ,
Regulation S-P ,
Remedial Actions ,
Reporting Requirements ,
Risk Alert ,
Risk Assessment ,
Risk Management ,
Sanctions ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Security Risk Assessments ,
Senior Managers ,
Servicing Agreements ,
Share Redemption ,
Shareholder Distributions ,
Swing Pricing
Non-Enforcement Advisers to Private Funds Among Targets of the SEC’s 2015 Examination Program The U.S. Securities and Exchange Commission (SEC) recently announced the 2015 examination priorities for its Office of Compliance...more
Renewed Call for Investment Adviser User Fees -
As we reported in previous editions of our Investment Management Newsletter, various persons have proposed that a user fee be imposed on SEC registered investment...more
Concerns Noted During Private Equity Adviser Exams -
Routine examinations by the SEC at advisory firms who manage the assets of private equity funds have uncovered some serious concerns about the way such advisers...more
5/30/2014
/ Enforcement ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Adviser ,
Mutual Funds ,
OCIE ,
Popular ,
Private Equity ,
Private Equity Funds ,
Professional License ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
SEC Initiates Enforcement Action Against Hedge Fund Adviser -
The SEC initiated an administrative proceeding on January 8, 2014 against Patrick G. Rooney (“Rooney”), the sole owner and managing partner of Solaris...more