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Policies and Procedures Internal Controls Dodd-Frank Wall Street Reform and Consumer Protection Act

Hogan Lovells

SEC grants no action relief from paragraph (a)(3)(iii) of Rule 192

Hogan Lovells on

The Securities and Exchange Commission has issued a no-action relief letter regarding paragraph (a)(3)(iii) of Rule 192 under the Securities Act of 1933, as amended. Rule 192, finalized in January 2024, implements Section 621...more

BCLP

SEC penalizes company with good disclosures for insufficient controls

BCLP on

What happened? In a recent settlement order, the SEC charged Activision Blizzard with failing to maintain adequate disclosure controls and procedures. Notably, the SEC did not claim that the company’s SEC filings were...more

Ballard Spahr LLP

OIG issues report on CFPB contract award controls; updated work plan includes evaluation of CFPB’s supervisory corrective action...

Ballard Spahr LLP on

The Office of Inspector General for the Fed and CFPB recently issued an audit report entitled “The CFPB Can Strengthen Contract Award Controls and Administrative Processes.” The objective of the OIG’s audit was to assess the...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

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