Tag Archives: compliance

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

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Update on PPP disclosure

FA Advisor magazine UPDATE TO THIS ARTICLE – THE DEADLINE TO RETURN HAS BEEN EXTENDED TO 5/14/20 Also, if you need to disclose the PPP loan on your ADV Part 2, it must be done within 30 days.  I believe … Continue reading

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SEC COVID-19 FAQ re PPP Loans

The SEC has come out with an FAQ regarding the disclosure of PPP loans.  Please read below.  If you are a client and need to have your ADV Part 2A updated to include a PPP disclosure, please let me know. … Continue reading

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 I know these are very tough times, with the markets down and towns going into quarantine mode. Here are a few tips from Jen Goldman of Jen Goldman Consulting, most which you all know.     TIPS:     1. make sure everyone knows … Continue reading

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New Hacking Incident – be VERY Aware

A client recently sent me an email asking about a blank form he received in the mail. It was a MA-W Notice of Withdrawal form (it is a form for withdrawing registration as a municipal advisor).  It was sent without … Continue reading

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SEC Exams and the DOL Rule

If your Policies and Procedures Manual says you do ‘X’ then you should be doing it.  In the past year I have added a policy for the DOL Rule to client Policies and Procedures Manuals.  Examiners have been asking about … Continue reading

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DOL Fiduciary Rule – update

Although it appears that the federal court decision vacating the DOL Fiduciary Rule was supposed to take effect on May 7, 2018, the DOL releases a statement continuing its policy of non-enforcement given “uncertainty about fiduciary obligations.” Firms that have … Continue reading

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News regarding DOL Fiduciary Rule

Yesterday, March 15, 2018, the U.S. Court of Appeals for the 5th Circuit voted 2-1 to vacate the DOL Fiduciary Rule.  HOWEVER,  the effect of the decision only applies to the following three states within the 5th Circuit’s jurisdiction – Louisiana, … Continue reading

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Cybersecurity Training Options

Cybersecurity is once again on the SEC’s OCIE exam priorities list.  There are many things that a firm can do to counter the concerns of Cybersecurity.  One of the most difficult items to counter is an employee and their inadvertent … Continue reading

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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

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