On December 20, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) of the Securities and Exchange Commission (“SEC”) issued its 2019 examination priorities letter. OCIE releases examination priorities...more
Investment Advisers Act Rule 206(4) (the “Custody Rule”) is designed to protect client funds and securities from being lost, misused, or otherwise misappropriated by investment advisers. As such, the Custody Rule provides...more
On Tuesday, February 13, 2018 the Securities and Exchange Commission (“SEC”) announced the opening of registration for its compliance outreach program’s national seminar for investment companies and investment advisers, which...more
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
On Tuesday, September 12th, Florida Governor Rick Scott directed Insurance Commissioner David Altmaier to “freeze any and all efforts” to increase property insurance rates. In addition, Governor Scott stated that...more
On Friday, September 7th, the Senate passed a bill increasing the disaster aid within the National Flood Insurance Program (the “NFIP”) to $15 billion. The NFIP was initially established in 1968 to provide flood coverage to...more
Hurricane Harvey has caused significant exposure for those owning habitational accounts in London’s direct and facultative (“D&F”) market. Habitational coverage insures commercial residential properties, and each habitational...more
On February 21, 2017 the Securities and Exchange Commission (the SEC) released new guidance concerning when a registered investment adviser is deemed to have “custody” for purposes of Adviser’s Act Rule 206(4) (the Custody...more
On August 25, 2016, the Securities and Exchange Commission (the “SEC”) adopted amendments to rules promulgated under the Investment Advisers Act of 1940 (the “Advisers Act”) and the investment adviser registration and...more
In connection with publication of final regulations (the Rule) on the definition of “fiduciary” under the Employee Retirement Income Security Act of 1974, as amended (ERISA) and the Internal Revenue Code of 1986, as amended...more
On April 8, 2016, the United States Department of Labor (Department) published its long-awaited final regulations (the Rule) redefining who is a “fiduciary” of an employee benefit plan under the Employee Retirement Income...more
The Office of Compliance Inspections and Examinations (the OCIE) has just published a new Risk Alert on cyber risks and precautions identifying specific areas it will be focusing on during the second round of examinations of...more