Cindi Hill
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Tag Archives: SEC regulations
Global Investment Performance Standards (GIPS®) Workshop
Don’t miss this opportunity to reserve your seat at an interactive workshop that offers a practitioner’s view of the GIPS® standards. Sessions have been organized covering GIPS compliance fundamentals and how to create and maintain a GIPS compliance program, with an in-depth review … Continue reading
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 as Custody – additional information
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
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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Five steps to take when you suspect you are a victim of a cyber attack
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
Posted in Uncategorized
Tagged cybersecurity, IA regulations, Investment Advisor, SEC regulations
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Firm Censured for Failing to Disclose Investment in Service Provider
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
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
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Tagged Chief Compliance Officer, compliance, due diligence, IA regulations, SEC regulations
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Preparing for Preliminary Renewal Reports
Time to prepare for the 2017 Renewals. The Preliminary Renewal Statement will be ready for viewing on Monday, November 14th. You may want to confirm that the states in which you are registered or noticed filed (if you are … Continue reading
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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