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Tag Archives: Chief Compliance Officer
10 Remote Compliance Best Practices
from Cipperman Compliance Services Today, we offer our “Friday List,” an occasional feature summarizing a topic significant to investment management professionals interested in regulatory issues. Our Friday Lists are an expanded “Our Take” on a particular subject, offering our unique … Continue reading
Coronavirus and Fraud
Be aware that opportunistic criminals are using the coronavirus pandemic to steal people’s money and identities. Here are some of the strategies you should be aware of: Outbreak maps. Don’t click on any link that purports to show a … Continue reading
Posted in Uncategorized
Tagged Chief Compliance Officer, Coronavirus, cybersecurity, phishing
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SEC Fines and Bars CCO for Ignoring Compliance Problems
from Cipperman Compliance Services The SEC fined and barred an adviser’s Chief Compliance Officer from acting in a compliance or supervisory capacity because of his failures to remedy compliance deficiencies. The adviser hired an outside compliance consultant which recommended 59 … Continue reading
Posted in Uncategorized
Tagged CCO, Chief Compliance Officer, compliance, Investment Advisor
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SEC Explores Ways to Strengthen Compliance of Independent Advisers
SEC Explores Ways To Strengthen Compliance Of Independent Advisers (Mark Schoeff, Investment News) – At a recent compliance conference, the acting director of the SEC’s Office of Compliance Inspections and Examinations (OCIE) noted that the SEC has increasing concern about … Continue reading
Standing LOAs Cause Advisers to Have Custody
from Cipperman Compliance Services LLC The staff of the SEC’s Division of Investment Management, in a recent No-Action Letter, has opined that an adviser has regulatory custody of client assets where a client grants even limited authority to transfer assets … Continue reading
Posted in Uncategorized
Tagged Chief Compliance Officer, compliance, custody, IA regulations, Investment Advisor, SEC regulations
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Consistency between Code of Ethics and Actual Gifts Received
from Cipperman Compliance Services The SEC censured and fined an investment consultant and its principal $700,000 for lying about gifts received from recommended investment managers and performance information. The respondent’s marketing material claimed that neither the firm nor its principals … Continue reading
Posted in Uncategorized
Tagged Chief Compliance Officer, IA regulations, Investment Advisor, SEC regulations
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Disaster Recovery testing opportunity
Today may be an opportunity to test your Disaster Recovery Plan – especially if you live in the North East. With the NorEaster, you, or some of your employees, may not be able to get to the office. Or you … Continue reading
SEC Reviewing Multi-Branch Adviser Compliance
SEC Reviewing Multi-Branch Adviser Compliance from Cipperman Compliance Services The staff of the SEC’s Office of Compliance Inspections and Examinations issued a Risk Alert announcing its “Multi-Branch Adviser Initiative.” The Alert expresses concern about the “unique risks and challenges” for … Continue reading
Posted in Uncategorized
Tagged Chief Compliance Officer, compliance, due diligence, IA regulations, SEC regulations
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Custody Rule Concerns
There has been a lot of discussion the last month or so about whether an advisor has custody, and therefore required to have an annual surprise custody audit. The SEC has in several exams stated that a custodian’s contract could … Continue reading
Posted in Uncategorized
Tagged Chief Compliance Officer, compliance, custody, SEC regulations
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Disaster Preparation
In an article published on FinancialPlanning October 7, 2016, Carolyn McClanahan discussed the action plan her firm had in place as Hurricane Matthew was bearing down on her city. Here are some ideas that you may want to consider. The … Continue reading
Posted in Uncategorized
Tagged Chief Compliance Officer, compliance, Disaster Recovery Plan, IA regulations
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