For most investment advisers, March signals the beginning of Form ADV season, where compliance officers gather all kinds of firm data to update a document fraught with potential regulatory liability. For the uninitiated, Form...more
Advisers Drafted by FinCEN for AML Duty, More Fines for E-Comm Retention Failures and a September Miracle, SEC Falls Back on Broken Windows Strategy, and a Refusal to Give Up on Private Fund Rules - FinCEN added to advisers’...more