5 Key Takeaways | 2024 Emerging Trends: Delaware Unclaimed Property VDA and Multistate Audits
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Compliance Tip of the Day: Machine Learning for Internal Audit
DE Under 3: OFCCP Changes Up Important Technical Details of its Audit Selection Process in First FY 2024 CSAL
Preparing for a Government Healthcare Audit
What Can A Tax Attorney Do For You? A Podcast With Janathan Allen
Navigating GSA Audits Compliance Strategies and Best Practices
DE Under 3: US DOL Inspector General’s Office Plans to Review Effectiveness of OFCCP Compliance Evaluations
DE Under 3: What Federal Contractors Need to Know About OFCCP's New Audit Scheduling Letter
DE Under 3: What’s New in OFCCP’s Latest Audit Scheduling Letter for Supply & Service Contractors
Independent Audits of Nonprofit Organizations With Douglas Cook
DE Under 3: U.S. OPM Proposed Allowing Federal Managers To Avoid Most Qualified Candidates To Pick Those Who Offer Better “Fit”
AGG Talks: Home Health & Hospice - Reimbursement Audits and Appeals
After ALJ: Options and Opportunities in the Face of an Unfavorable ALJ Decision
The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Compliance and Managing from the Middle
I Understood There Would Be No Math: Audits, Extrapolations, and a New Set of Rules
JONES DAY PRESENTS®: Trade Secret Audits: Enhanced Mapping, Protecting Access and Creating Understanding
Constangy Webinar - DEI Audits: Tools to Enhance Your DEI Practices
[Podcast] New Year, New PAC: Have a Successful PAC Audit in 2023
On November 1, 2023, the industry groups (the Petitioners) challenging the new Private Fund Adviser Rules filed in the US Court of Appeals for the Fifth Circuit their opening brief (the Brief) setting forth their legal...more
The US Securities and Exchange Commission (“SEC”) recently finalized sweeping new rules for private fund advisers (the “PFA Rules”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The PFA Rules...more
On September 5, 2023, almost one year since its first flurry of similar Custody Rule actions, the SEC announced settlements with five SEC-registered investment advisers to private funds with respect to alleged violations of...more
On August 23, 2023, the U.S. Securities and Exchange Commission (SEC) announced the enactment of a series of new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act). We refer to these...more
The SEC (U.S. Securities and Exchange Commission) has provided notice that it is preparing to adopt the so-called “Private Funds Rules” under the Investment Advisers Act of 1940 (the “Advisers Act”) on August 23, 2023....more
The U.S. Securities and Exchange Commission, by a vote of four-to-one, proposed a major overhaul of the investment adviser custody rule on February 15, 2023. The proposal would amend and redesignate Rule 206(4)-2 under the...more
Regulatory Developments - OCC Releases Strategic Plan for Fiscal Years 2023-2027 - On September 6, the OCC released its strategic plan for the next five years, covering fiscal years 2023-2027 (the Plan)....more
On November 2, 2020, the SEC’s Division of Enforcement issued its 2020 Annual Report for the fiscal year ending September 30, 2020. While the Enforcement Division filed 405 standalone enforcement actions – the lowest total in...more
A U.S. Securities and Exchange Commission (SEC) no-action letter issued on April 25, 2016 provides relief from the annual surprise audit requirement of the “Custody Rule” for a registered investment adviser (RIA)...more
The SEC announced charges against an investment advisory firm and three of its top officials for violating the “custody rule” that requires firms to follow certain procedures when they control or have access to client money...more
The SEC brought another in what may become a series of custody rule cases. This action was brought against Professional Investment Management, Inc., and its principal, Douglas Cowgill. SEC v. Cowgill, Case No. 2:14 CV 396...more
On August 1, 2013, the Division of Investment Management of the Securities and Exchange Commission published an IM Guidance Update (the “Update”) regarding Rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act...more
The SEC’s Office of Compliance Inspections and Examinations reports finding widespread compliance deficiencies related to custody of securities. In its March 4, 2013 National Exam Program Risk Alert, OCIE said that...more
The SEC has issued a Risk Alert on compliance with its custody rule for investment. It notes that with respect to advisers to audited pooled investment vehicles, its examinations found some failed to meet requirements to...more