Tag Archives: SEC regulations

SEC Explores Ways to Strengthen Compliance of Independent Advisers

Posted on April 17, 2017 by

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 →

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Standing LOAs as Custody – additional information

Posted on February 23, 2017 by

The No-Action Letter discussed in yesterday’s blog contains seven conditions that, if met, would allow an adviser to escape the need for a surprise exam: 1. The client provides an instruction to the qualified custodian, in writing, that includes the … Continue reading →

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Standing LOAs Cause Advisers to Have Custody

Posted on February 22, 2017 by

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 →

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Consistency between Code of Ethics and Actual Gifts Received

Posted on February 10, 2017 by

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 →

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Five steps to take when you suspect you are a victim of a cyber attack

Posted on January 27, 2017 by

from IAWatch Step 1: Contact your IT leader. Step 2: Assess if your system has been penetrated. Step 3: Detect the extent of the hack. Step 4: Notify clients – be aware of your state’s laws regarding alerting a client … Continue reading →

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Firm Censured for Failing to Disclose Investment in Service Provider

Posted on January 11, 2017 by

from Cipperman Compliance  The SEC fined and censured a private equity fund manager for failing to disclose that the principals had personally invested in an IT firm that it had engaged. The respondent utilized the IT firm to perform due … Continue reading →

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SEC Reviewing Multi-Branch Adviser Compliance

Posted on January 6, 2017 by

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 →

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