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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SEC Requirement: Annual Amendment for Form ADV 2024

The SEC requires that investment advisers file a form ADV Annual Amendment within 90 days of the end of the adviser’s fiscal year. If your fiscal year ended Dec. 31, you will be required to file an annual amendment to your Form ADV by March 30, 2024.

New Rule 13f-2 and Form SHO

Stay up to date on SEC and compliance-related news, including SEC exam topics, the SEC Marketing Rule, and more, with our News and Flash Reports.

Reminder about the “13s” due February 14, 2024

The are a number of filing deadlines coming up next month for the “13s”. As of February 5, 2024, the filing deadline for Schedule 13Ds, Schedule 13Gs, and their respective amendments will be extended from 5:30PM EST to 10:00 PM EST.

Exempt Reporting Advisers and Private Fund Reforms: The Requirements That Attach for any Manager of a Private Fund

On August 23, 2023, a divided SEC voted to adopt enhanced regulations of private fund advisers. These included two rules that all investment advisers managing private funds must follow: the Preferential Treatment Rule and the Restricted Activities Rule. 

Four-Step Guide to Investment Adviser Compliance Program Readiness

Last year was a busy year for the SEC, and 2024 is expected to be even busier. The New Year is a great time to take a fresh look at your compliance program to make sure you are meeting the most up-to-date best practices, and to ensure you are prepared for regulatory inspection.

2024 Cyber and Data Security Program Checklist

As you finalize your goals and planning for 2024, make sure that your cyber and data security program is a key component of your plan. As regulatory requirements continue to change, and as online hackers become even more sophisticated, it is absolutely critical that your cyber and data security programs meet industry best practices.

Year in Review

2023 was a busy year for the SEC. From the sweeping Private Fund Adviser Rules to the SEC’s proposed predictive analytics rules and more, investment advisers are in for a busy 2024 as well.

The Biggest Cyber Trends in 2024 to Prepare for Now

Cybersecurity is already topping the list as one of the greatest risks to businesses. 2024 will be no different—in fact, by the end of the coming year, the cost of cyber-attacks on the global economy is predicted to top 10.5 trillion. In addition to existing threats, artificial intelligence (AI) will continue to grow and evolve in the coming year, and businesses need to be prepared.

Regulation S-P Overview

Regulation S-P became effective on November 13th, 2000, and requires financial institutions to provide notice to customers regarding the financial institution’s privacy policies; the condition under which they may disclose nonpublic personal information about consumers to nonaffiliated third parties; and provide an “opt out” method for consumers to prevent the financial institution from disclosing information.  

Reminder: Annual IAR Continuing Education Requirements

Time to ask IARs if they have completed annual Continuing Education (“CE”) requirements. Eleven states have continuing education requirements for Investment Adviser Representatives (“IARs”) with final effective dates. Even more jurisdictions have planned or passed a CE requirement for the future. Notices have already been sent to IARs with a CE requirement.

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Regulatory Calendar

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