Steps Your Nonprofit Can Take to Mitigate Fraud Risks - Part 2
A Third Party's Perspective on Third Party Risk
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
Consumer Finance Monitor Podcast Episode: Why do Fintechs Want to Become Banks?
Privacy Issues from Third-Party Website Tags
What's the Tea in L&E? Employee Devices: What is #NSFW?
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Video: Artificial Intelligence Use in Political Campaigns
Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility
Compliance Lessons from Dating in Your 50s
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The AI Shakeup: New Tech Innovations and the Future of Corporate Law
Principled Podcast: S11E7 | Fortifying Ethical Frameworks: Navigating Emerging Risks in the Middle East
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Navigating Bank-Fintech Partnerships: Avoiding Common Pitfalls — The Consumer Finance Podcast
Episode 326 -- Dottie Schindlinger on Diligent's Report on Board Oversight of Cybersecurity Risks and Performance
Revisiting Financial Institution Incentive Compensation Rules Under Dodd-Frank — The Consumer Finance Podcast
Episode 325 -- AI and Emerging Compliance Frameworks
On October 16, 2023, the Division of Examinations (the "Division") of the U.S. Securities and Exchange Commission ("SEC") released its 2024 Examination Priorities ("Annual Priorities").[1] Unlike in previous years when the...more
The United States Securities and Exchange Commission’s Division of Examinations announced its examination priorities for fiscal year 2024 on October 16, 2023. The timing of the announcement is significant because it is the...more
The Cayman Islands Monetary Authority (CIMA) recently issued a new Statement of Guidance for Mutual Funds and Private Funds (Corporate Governance Guidance) which: - updates the current guidance applicable to funds...more
On May 5, 2023, the Securities and Exchange Commission (the “SEC”) announced its first enforcement action against an investment adviser for violations of Rule 22e-4(b) (the “Liquidity Rule”) of the Investment Company Act of...more
Consider multiple bank relationships. Consider putting in place one or more additional banking relationships. Consider banking with an institution that maintains excess deposit insurance. Massachusetts-chartered savings...more
Our earlier blog post, “Companies Should Know Benefits and Risks of ESG Reporting,” provided an overview of the Environmental, Social and Governance (“ESG”) metrics, why these metrics are important to companies and...more
Crypto currency continues to be debated - some believe in it; others do not. The decision by the founder of Tesla to exit the market recently seems to have added a new element, however. Now the question is if crypto is energy...more
On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more
On October 28, 2020, the U.S. Securities and Exchange Commission (the SEC) voted 3-2 to adopt Rule 18f-4 (the Final Rule) under the Investment Company Act of 1940 (the 1940 Act), which establishes a comprehensive framework...more
The SEC voted to propose a rule designed to enhance the regulation of the use of derivatives by registered investment companies, including closed-end funds, as well as mutual funds, ETFs and business development companies....more
On September 9, 2019, the Staff (“Staff”) of the Securities and Exchange Commission (“SEC”) Division of Investment Management provided guidance (the “Guidance”) on how to improve principal fund risk disclosures to be more...more
Last week, the Financial Crimes Enforcement Network (FinCEN) and its regulatory partners issued a joint statement in an effort to increase transparency around risk-focused Bank Secrecy Act/anti-money laundering supervision....more
Best Practices: Lessons Learned from Litigation (#2)—the Vanderbilt Case - I am writing two series of articles that together are called “The Bests.” One is about Best Practices for Plan Sponsors, while the other is about...more
Best Practices: Lessons Learned from Litigation—the Anthem Case - I am writing two series of articles that together are called “The Bests.” One is about Best Practices for Plan Sponsors, while the other is about the Best...more
I have written before about the troubling lack of clarity regarding the tangible benefit of self-reporting rule violations to FINRA. While FINRA purports to provide some potential advantage for doing so, it is so awfully...more
Editor's Note - Modest Proposals. Last week, federal banking regulators issued two proposals that would substantively amend certain regulatory capital regulations applicable to the nation’s largest banks. On April 10, the...more
New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more
Implementing the U.S. Securities and Exchange Commission’s (SEC) fund liquidity risk management rules presents distinct challenges for open-end mutual funds and exchange-traded funds (ETFs), and compliance with the rules will...more
On March 22, the Securities and Exchange Commission (“Commission”) adopted a rule amendment that shortens the time by which most securities transactions effected by a broker-dealer are required to settle. Under the amendment,...more
On October 13, the SEC adopted rule reforms designed to improve liquidity risk management by open-end funds. Liquidity Risk Management Programs - Under the reforms, mutual funds (excluding money market funds) and...more
On January 4, new President and CEO Richard Cook issued FINRA’s Annual Regulatory and Examination Priorities Letter. This year’s list in summary is: New for 2017: Targeted electronic off-site reviews “on select...more
Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more
On October 13, 2016, the U.S. Securities and Exchange Commission (Commission) unanimously adopted regulatory changes that require open-end funds, including traditional mutual funds and exchange-traded funds, to establish...more
Editor's Note - Another Cybersecurity Proposal. On the heels of the New York State Department of Financial Services (NYDFS) issuing its proposed regulation that would require banks and insurance companies to institute...more
On October 13, 2016, the U.S. Securities and Exchange Commission (SEC) unanimously adopted regulatory changes that require open-end funds, including mutual funds and exchange-traded funds (ETFs), to establish liquidity risk...more