On June 5, 2019, the Securities and Exchange Commission (SEC) adopted a comprehensive interpretation (the “Interpretation”) of the fiduciary duties that investment advisers owe to their clients under the Investment Advisers...more
6/13/2019
/ Best Interest Standard ,
Broker-Dealer ,
Conflicts of Interest ,
Duty of Care ,
Duty of Loyalty ,
Enforcement Actions ,
Fiduciary Duty ,
Financial Services Industry ,
Informed Consent ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Retail Investors ,
Securities and Exchange Commission (SEC)
• On December 14, the SEC’s OCIE issued a Risk Alert summarizing the findings of its limited-scope examination initiative relating to electronic messaging.
• Noting a “pervasive use” of electronic messaging by adviser...more
12/18/2018
/ Best Practices ,
Books & Records ,
Bring Your Own Device (BYOD) ,
Cybersecurity ,
Electronic Communications ,
Email Policies ,
Employee Training ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
New Guidance ,
OCIE ,
Policies and Procedures ,
Recordkeeping Requirements ,
Risk Alert ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Text Messages
Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more
10/20/2015
/ Affiliates ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Bank Secrecy Act ,
Chief Compliance Officers ,
Compliance ,
Conflicts of Interest ,
CPO ,
Cybersecurity ,
Department of Justice (DOJ) ,
Export Controls ,
FATCA ,
FinCEN ,
Foreign Affiliates ,
Foreign Investment ,
General Solicitation ,
Investment Adviser ,
Investment Funds ,
Patriot Act ,
Policies and Procedures ,
Private Funds ,
Proxy Voting Guidelines ,
Reporting Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
Social Media Policy ,
Whistleblowers
Just one week after the Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations issued a new risk alert on cybersecurity, the SEC brought an enforcement action against an investment adviser...more
On April 28, the Securities and Exchange Commission (SEC) Division of Investment Management (the “Division”) published a Guidance Update setting forth cybersecurity concerns and advice for the registered investment ...more
Introduction -
Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past...more
10/6/2014
/ Affiliates ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Broken Windows ,
Chief Compliance Officers ,
CPO ,
Cybersecurity ,
Export Controls ,
FATCA ,
Foreign Affiliates ,
Foreign Investment ,
General Solicitation ,
Investment Adviser ,
Policies and Procedures ,
Private Funds ,
Proxy Voting Guidelines ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Social Media Policy
The U.S. Department of the Treasury requires U.S. resident issuers (including U.S. resident investment funds) and investment advisers managing foreign investment funds to report foreign residents’ holdings of U.S. securities,...more