Registration, Disclosure and Filing Requirements

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Large Trader Compliance Risks For Investment Advisers and Broker-Dealers

Large Trader Compliance Risks For Investment Advisers and Broker-Dealers WHAT HAPPENED? Recently, the Division of Enforcement of the U.S. Securities and Exchange Commission released a list of common compliance concerns noted during examinations of large traders, particularly with respect to Rule 13h-1. The Rule requires firms or individuals who [...]

The SEC’s New Marketing Rule: Here’s What You Should Know Now

The SEC’s New Marketing Rule: Here’s What You Should Know Now WHAT HAPPENED? On Dec. 22, 2020, the U.S. Securities and Exchange Commission unanimously voted to pass proposed amendments to the advertising and cash solicitation rules, along with updates to other requirements for registered investment advisers. The formerly separate rules are [...]

2020 Compliance Round Up: The Top 10 Regulatory Headlines for Investment Advisers This Year

2020 Compliance Round-Up: The Top 10 Regulatory Headlines for Investment Advisers This Year WHAT HAPPENED? Amid the unique changes and challenges 2020 has brought, there has been plenty of regulatory news from the U.S. Securities and Exchange Commission and the Office of Compliance Inspections and Examinations (OCIE) in the [...]

SEC exam trends: 5 areas of focus for RIAs

SEC exam trends: 5 areas of focus for RIAs WHAT HAPPENED? Although routine examinations may include requests related to any area of your firm’s operations, examiners may focus on certain compliance risks that have been identified or those itemized in a Risk Alert. Staying up to date with SEC [...]

OCIE Risk Alert: common compliance program issues

OCIE Risk Alert: common compliance program issues WHAT HAPPENED? On Nov. 19, 2020, the Office of Compliance Inspections and Examinations of the U.S. Securities and Exchange Commission (OCIE) released a Risk Alert outlining common compliance concerns among registered investment advisers. The list was compiled based on recent compliance examinations [...]

OCIE examiners report common branch office compliance deficiencies

OCIE examiners report common branch office compliance deficiencies WHAT HAPPENED? On Nov. 9, 2020, the Office of Compliance Inspections and Examinations of the U.S. Securities and Exchange Commission (OCIE) released a new Risk Alert outlining recent observations from examinations of SEC-registered investment advisers. In general, advisers with numerous branch [...]

Are your documents and website up to ADA standards?

Are your documents and website up to ADA standards? WHAT HAPPENED? Clients and shareholders with auditory, cognitive, neurological, physical, speech, and visual impairments use assistive devices, like screen readers, screen magnifiers, and Braille displays, to consume content produced by your firm. Certain technical criteria are required to be met [...]

SEC proposes exemption for finders helping small businesses raise capital

SEC proposes exemption for finders helping small businesses raise capital WHAT HAPPENED? On Oct. 7, 2020, the U.S. Securities and Exchange Commission proposed a conditional exemption which would allow certain market participants to be exempted from registering as brokers under federal securities laws. The exemptions would benefit “finders” who [...]

Newly Identified Compliance Risks Due to COVID-19: What You Should Know

Newly Identified Compliance Risks Due to COVID-19: What You Should Know WHAT HAPPENED? Last week, the Office of Compliance Inspections and Examinations of the United States Securities and Exchange Commission (OCIE) issued a Risk Alert which outlines new compliance risks stemming from the global pandemic. The SEC and OCIE have remained [...]