News & Insights: Compliance Administration

LIBOR Transition Compliance Risks

On June 18, 2020, the OCIE announced an exam initiative and issued a subsequent Risk Alert about LIBOR transition preparedness.

OCIE: Private Fund Risk Alert

The OICE, released a Risk Alert that outlines recently observed compliance issues among private fund advisers. Over a third of SEC-registered advisers manage private funds, marking them as a special focus for OCIE.

Our Firm Filed Form CRS – What Now?

Retail advisers and their service providers have put much time and effort into understanding, writing, and filing the initial Form CRS document. The requirements related to the Form do not stop once the filing is complete; several additional steps must be taken after submitting the form to the SEC.

Firm Misused MNPI, Ordered to Pay $1 Million

On May 26, 2020, the United States Securities and Exchange Commission released documentation detailing an enforcement action against a Los Angeles private equity firm and registered investment adviser, Ares Management, for its misuse of material nonpublic information (MNPI).

Adviser Fined $60,000 for Custody Rule Violation

On May 22, 2020, the SEC published information on an enforcement action against a registered investment adviser. The firm was investigated, and subsequently disciplined by the SEC for violating the Custody Rule.

UPDATE: SEC Provides Guidance on Advisory Firms Accepting PPP Loans

Many investment advisers have applied for or accepted a Paycheck Protection Program (“PPP”) loan for their firm.

SEC Proposes Rule to Modernize Fund Valuation Practices

The SEC is taking steps to improve the requirements. The rule intends to aid retail investors in gaining fair and complete information about their fund investments by making fund information more accurate and accessible.

SEC Makes Updates to Regulatory Relief Guidance

The SEC updated a set of frequently asked questions (“FAQs”) to guide COVID-19 regulatory relief.

Annual FINRA Entitlement User Accounts Certification – 2020

he FINRA Entitlement Program requires an annual review and certification of user accounts to ensure that all persons with access to FINRA applications, such as the IARD portal, are approved by the Super Account Administrator (SAA) of the adviser.

SEC Updates Custody Rule FAQs to Address COVID-19 Concerns

The SEC updated FAQs on custody rule requirements in response to the pandemic.

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