News & Analysis as of

Chief Compliance Officers Risk Alert

SEC Compliance Consultants, Inc. (SEC³)

SEC Tells Advisers What Not to Do in Advertisements

SEC’s Division of Examinations (“EXAMS”) issued a risk alert on its Initial Observations Regarding Advisers Act Marketing Rule Compliance (the “Risk Alert”), giving compliance officers an unexpected gift by sharing examples...more

Goodwin

SEC’s Division of Examinations Issues Risk Alert Regarding MNPI and Code of Ethics Compliance

Goodwin on

On April 26, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) issued a risk alert concerning deficiencies related to Section 204A of the Investment Advisers Act of 1940 (“Advisers...more

Eversheds Sutherland (US) LLP

SEC’s focus on compliance: What boards should know

Rule 38a-1 under the Investment Company Act of 1940 (the 1940 Act) requires funds to review their compliance programs, as well of those of their service providers, including their investment advisers (advisers), annually....more

Akerman LLP

SEC Division of Examinations Calls Out Compliance Weaknesses and Spells Out Expectations Moving into 2021

Akerman LLP on

The SEC's Division of Examinations recently issued a Risk Alert with observations on investment adviser compliance programs, noting numerous deficiencies and weaknesses it has encountered....more

Proskauer Rose LLP

OCIE Issues Risk Alert on Common Deficiencies Observed in Adviser Compliance Programs

Proskauer Rose LLP on

On November 19, 2020, the SEC published a risk alert providing an overview of notable compliance issues identified by the agency’s Office of Compliance Inspections and Examinations (“OCIE”) under Rule 206(4)-7 (the...more

Dorsey & Whitney LLP

SEC on Compliance

Dorsey & Whitney LLP on

Compliance is a key issue for all firms. Many companies use the U.S. sentencing guidelines as a starting point. In other instances, regulators craft a starting point with rules that direct the creation of programs....more

Faegre Drinker Biddle & Reath LLP

The SEC’s CCO Guidance Month

In a 30-day period, the U.S. Securities and Exchange Commission (“SEC”) has released guidance in three ways regarding certain views on the important role and potential liability risks of chief compliance officers (“CCOs”)....more

Sheppard Mullin Richter & Hampton LLP

OCIE Director Instructs Advisers to Empower Chief Compliance Officers

On November 19, 2020, Peter Driscoll, director of the Office of Compliance Inspection and Examination (“OCIE”) of the Securities and Exchange Commission (“SEC”), gave a speech urging advisory firms to empower their Chief...more

Kramer Levin Naftalis & Frankel LLP

Funds Talk: March 2017

OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more

Dorsey & Whitney LLP

Common Compliance Issues for Investment Advisers

Dorsey & Whitney LLP on

On February 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert listing the five most frequent compliance topics identified on investment adviser examinations completed within...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

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

Morgan Lewis

SEC Exam Staff Shares Observations on Outsourced Chief Compliance Officers

Morgan Lewis on

Firms that use third-party CCOs or that rely on financial intermediaries that have outsourced their compliance functions should consider taking a fresh look at their compliance structure in the wake of this guidance....more

Foley Hoag LLP

OCIE Issues Risk Alert Relating to Outsourced Chief Compliance Officers

Foley Hoag LLP on

On November 9, 2015, the Office of Compliance Inspections and Examinations (“OCIE”) released the findings of its Outsourced CCO Initiative, which examined nearly 20 investment advisers and investment companies that are...more

Goodwin

SEC Releases Risk Alert Related to Outsourcing of Chief Compliance Officer Duties by Investment Advisers and Investment Companies

Goodwin on

On Nov. 9, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert reporting observations from its examination of investment advisers and investment companies that outsource their Chief...more

Goodwin

Financial Services Weekly News - November 2015 #2

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Regulatory Developments: CFTC and NFA Staff Publish FAQs and Other Resources for Filing and Reporting on Forms CPO-PQR and CTA-PR - On Nov. 5 the Division of Swap Dealer and Intermediary Oversight of the CFTC...more

Broker-Dealer Compliance + Regulation

OCIE Cautions Advisers About Outsourcing Compliance Activities

In a Risk Alert dated November 9, 2015, the SEC’s Office of Compliance Inspections and Examinations (OCIE) said it found that outsourced compliance programs are generally effective, but some of these arrangements leave room...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

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

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