[WEBINAR] Annual Labor & Employment Update
ethikos 34, no. 2 (February 2020) - In January, the U.S. Securities and Exchange Commission (SEC) announced its 2020 examination priorities, published annually “to enhance the transparency of its examination program and to...more
The Situation: The U.S. Securities and Exchange Commission's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") issued its 2020 examination priorities ("Exam Priorities"). The Result: The Exam Priorities...more
The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more
Financial institutions and their employees may be subject to the following federal pay-to-play rules: SEC Rule 206(4)-5 for investment advisers; CFTC Rule 23.451 for commodities-backed swap dealers; FINRA Rule 2030 for...more
On February 7, 2018, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) released its 2018 examination priorities. This year’s priorities comprise five principal areas: (1)...more
On January 8 and February 7, 2018, respectively, the Financial Industry Regulatory Authority (“FINRA”) and the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”)...more
On February 7, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) published its 2018 examination priorities. OCIE’s examination priorities are...more
On September 19, 2016, the Municipal Securities Rulemaking Board ("MSRB") advised Congress that it had "just concluded development of a core regulatory framework for municipal advisors." This by no means signals a significant...more
The Sixth Circuit this week declined the SEC’s request to dismiss a Constitutional challenge to the new MSRB pay-to-play rules. Instead, the Court ordered the case to a merits panel for consideration. The Republican parties...more
The SEC announced August 25 that it approved FINRA’s pay-to-play rules governing placement-agent or solicitor broker-dealers and was “prepared” to approve the extension of MSRB Rule G-37 to municipal advisors as well....more
As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political activities by their personnel which could raise...more
Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more
On June 25, 2015, the Securities and Exchange Commission (SEC) set a compliance date of July 31, 2015 for the ban on payments to third parties for the solicitation of advisory business from any government entity under Rule...more
The Securities and Exchange Commission’s Rule 206(4)-5 (Pay-to-Play Rule) under the Investment Advisers Act of 1940, as amended, prohibits, among other restrictions, an investment adviser subject to the rule, and its covered...more
In This Issue: - SEC Announces First-of-Its-Kind Whistleblower Award To an Audit and Compliance Professional - SEC Issues No-Action Letter To Allow for Amendment of a Sub-Advisory Agreement without Shareholder...more