Rethinking Records Retention
Compliance Tip of the Day: Internal Controls for GTE
FCPA Compliance Report: Revolutionizing Speak Up: Ariel D. Weindling on Enhancing Whistleblower Systems
Compliance Tip of the Day: Implementing Internal Controls
Podcast: Addressing Patient Complaints About Privacy Violations
Compliance Amidst a Global Consensus Breakdown
Compliance Tip of the Day: What are Internal Controls?
Compliance Tip of the Day: Compliance Training Frequency
Compliance Tip of the Day: Design Objectives for Compliance Training
FCPA Compliance Report: The Power of Peer Support and Purpose Driven Leadership with Sarah Cole
Innovation in Compliance: Innovative Approaches to Compliance and Training with Catherine Choe
Compliance Tip of the Day: Multiplying the Influence of Compliance
Compliance tip of the Day: Communication Through Persuasion
Compliance Tip of the Day: Empowering Middle Managers to Drive Compliance Transformation
Compliance Tip of the Day: Middle Managers as the Eyes and Ears of Compliance
Compliance Tip of the Day – Role of Chatbots in Compliance
Beyond the Bylaws: The Medical Staff Show | The Role of Bylaws in Medical Staff Governance, Part II
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
Compliance Tip Of the Day: Using AI to Transform Whistleblower Response
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
Chief Compliance Officers face the challenge of running a comprehensive yet efficient compliance program that nimbly adapts to changing regulatory requirements and business practices. As compliance consultants, we see our...more
In a two-part legal update, we will discuss key information SEC registrants should know going into the upcoming review cycle conducted by the Division of Examinations (the Division). This first update attempts to demystify...more
On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) issued its annual examination priorities for fiscal year 2025. As with its 2024 examination...more
On April 17th, the SEC issued a Risk Alert titled “Initial Observations Regarding Advisers Act Marketing Rule Compliance.” Perusing the list of failures, a sense of familiarity arose, given that one of our clients had been...more
Rule 206(4)-1, as amended (the Marketing Rule), continues to be an area of focus for the U.S. Securities and Exchange Commission (SEC). On April 17, 2024, the SEC Division of Examinations (Division) published a risk alert...more
On October 16, 2023, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) published its annual Examination Priorities for 2024 (the “Exam Priorities”). Consistent with the...more
The US Securities and Exchange Commission (SEC) Division of Examinations recently released its 2024 Examinations Priorities, a yearly report that provides insight into the Division’s areas of focus to improve compliance,...more
On September 6, 2023, the SEC Division of Examinations (the “Division”) published a Risk Alert entitled “Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents” (the “Alert”). This Alert offers...more
On June 8, 2023, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“Division”) released a risk alert (the “Risk Alert”) outlining the SEC’s broadened examination priorities with respect to revised...more
On March 27, 2023, the SEC’s Division of Examinations (the “Division”) issued a Risk Alert on its observations from examinations of newly-registered advisers. The Division focused on whether newly-registered advisers...more
On September 19, 2022, the Securities and Exchange Commission’s Division of Examinations (the “SEC”) published a Risk Alert announcing its intent to conduct examinations focused on compliance with Rule 206(4)-1 (the...more
The SEC recently published its 2022 Examination Priorities Letter on the heels of FINRA issuing its 2022 Examination and Risk Monitoring Program Report. One of many areas of common focus is financial management, and more...more
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
SEC Chair Gary Gensler has not publicly stated much regarding Reg BI since Spring of this year. Generally, though, the messaging from SEC leadership regarding the Division of Examinations and the Division of Enforcement...more
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
Why It Matters - Broker-dealers and investment advisers should take heed of OCIE’s guidance and assess their compliance policies and procedures accordingly. Compliance should consider, in consultation with their counsel,...more
On November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert outlining its top compliance observations from examinations of nearly 300 registered funds conducted over a two-year...more
In a Risk Alert dated November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations reminded investment company advisers and boards that examiners are looking carefully at how firms approach and document the...more
On January 12, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published its 2017 examination priorities.1 OCIE’s 2017 priorities, which largely mirror its 2016 priorities, cover three areas: (1)...more