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CFA Institute Issues Guidance Statement on Broadly Distributed Pooled Funds

CFA Institute Issues Guidance Statement on Broadly Distributed Pooled Funds WHAT HAPPENED? The CFA Institute has recently released a guidance statement on broadly distributed pooled funds for firms that manage one or more pooled funds and influence the official pooled fund documents or fund-specific marketing materials. A broadly distributed pooled fund is [...]

CCO Charged with Inadequate Form ADV Disclosures

CCO Charged with Inadequate Form ADV Disclosures WHAT HAPPENED? On March 29, 2017, the SEC charged the dually-acting principal and Chief Compliance Officer of Alison, LLC, with failing to provide specific books and records to the Commission’s examination staff. In addition, the examination concluded that the registered investment adviser’s Form ADV failed [...]

Applicability of the Fiduciary Rule Extended

Applicability of the Fiduciary Rule Extended WHAT HAPPENED? On April 5, 2017, the Department of Labor issued a 60-day delay of the Fiduciary Rule’s applicability date to June 9, 2017. This extension applies to related exemptions as well, including the Best Interest Contract Exemption. The Department of Labor will use this time [...]

SEC Releases ‘No-Action’ Letter Concerning the Custody Rule

SEC Releases ‘No-Action’ Letter Concerning the Custody Rule WHAT HAPPENED? On February 21, 2017, the SEC released a ‘no-action’ letter to address confusion surrounding the Investment Advisers Act Rule 206(4)-4 (the “Custody Rule”) and its requirements for first-party money movement and third-party money movement.  The letter is intended to [...]