News & Insights

Check out our Flash Reports for the latest SEC- and compliance-related news, trends, and insights.

SEC Adopts Rule Amendments to Regulation S-P to Enhance Protection of Customer Information

The SEC adopted amendments to Regulation S-P requiring broker-dealers, investment companies, registered investment advisors, and transfer agents to implement and maintain policies and procedures regarding an incident response program that are designed to detect, respond, and recover from unwarranted access or use of client information.

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FINRA Cites Unreasonable Email Review

On April 12, 2019, the Financial Industry Regulatory Authority (“FINRA”) issued a settlement with a Salt Lake City-based broker-dealer, due to poorly designed and implemented email review procedures.

FINRA’s 2019 Entitlement User Accounts Certification

The FINRA Entitlement Program requires an annual review specifically evaluates that users have an ongoing need to access FINRA applications, may access only applications which are essential to job functions, and that users are authorized to access sensitive information, if necessary.

OCIE Warns Advisers and Broker-Dealers of Regulation S-P Compliance Issues

Regulation S-P requires registered investment advisers, investment companies, and broker-dealers to provide notice to customers and maintain written records of policies and procedures related to information privacy.

SEC Officials Comment on Evolving Proxy Voting Process

SEC Commissioner Elad Roisman and Director of the Division of Investment Management, Dalia Blass, spoke on the future of the proxy voting process.

Reminder: Annual Brochure Delivery Obligation

For Advisers with a fiscal year ending Dec. 31, the annual brochure delivery deadline is approaching on April 30.

Large Cash Flows versus Significant Cash Flows: Which is Which?

The GIPS standards define a large cash flow as the level at which the firm determines that an external cash flow may distort performance if the portfolio is not valued.

IARD and PFRD Systems Inaccessible 3 weekend in April

The SEC announced that the IARD and PFRD systems will be unavailable during three weekends in April, plus Good Friday.

BB&T Subsidiary Must Pay $5.7 Million After Policy Violation

The SEC ordered BB&T Securities to pay $5.7 million following Valley Forge Asset Management’s intentional overcharging of clients.

Best Practices for Meeting the Distribution Requirement

Global Investment Performance Standards (GIPS®) Provision 0.A.9. requires firms to make every reasonable effort to provide a compliant presentation to all prospective clients.

SEC Requirement: Annual Amendment for Form ADV 2019

 If your fiscal year ended December 31, you will be required to file an annual amendment to your Form ADV by March 31, 2019.

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