Registration, Disclosure and Filing Requirements

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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 [...]

Open-End Funds: Proposed Amendments to Reporting and Disclosure Requirements

Open-End Funds: Proposed Amendments to Reporting and Disclosure Requirements WHAT HAPPENED? On Aug. 5, 2020, the United States Securities and Exchange Commission proposed a new set of amendments to mutual fund and exchange-traded fund disclosure requirements. The package includes, among other things, changes to visual presentation requirements and the [...]

SEC Proposes Changes to Form 13F

SEC Proposes Changes to Form 13F WHAT HAPPENED? On July 10, 2020, the United States Securities and Exchange Commission proposed amendments to Form 13F reporting. The changes would affect the filing threshold for institutional advisers and several other requirements. Because the filing requirements have not been updated since adoption [...]

Our Firm Filed Form CRS – What Now?

Our Firm Filed Form CRS - What Now? WHAT HAPPENED? Initial filings of Form ADV Part 3 (Form CRS) are due by June 30, 2020. For months, retail advisers and their service providers have put much time and effort into understanding, writing, and filing the initial Form CRS document. [...]

Risk Alerts From OCIE: Form CRS and Reg BI

Risk Alerts From OCIE: Form CRS and Reg BI WHAT HAPPENED? On April 7, 2020, the Office of Compliance Inspections and Examinations (OCIE) of the United States Securities and Exchange Commission released two Risk Alerts to address upcoming compliance expectations for the new Form CRS and Regulation Best Interest [...]