The Role of the CCO

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From a recent speech by the the head of the SEC’s Office of Compliance Inspections and Examinations (now known as the Examinations Division):

Summary of SEC Releases

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The past few years have seen quite a bit of regulatory activity. The SEC’s Office of Compliance Inspections and Examination (now known as the “Office of Examinations”) issued nine Risk Alerts in 2020, five in 2019 and five more in … Continued

2019 SEC Examination Priorities

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The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission has released its 2019 examination priorities. You will not be surprised to see that cybersecurity is still on the list. Anti-money laundering will also figure … Continued

Way to Go CCO Companion!

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Congratulations to the team at Digital Compliance and the launch of their very first compliance app – CCO Companion. We are proud to be the sole content provider for all of CCO Companion’s original compliance material. We believe, and from early … Continued

Conduct Compliance Testing

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“Forensic testing” is certainly the buzzword in compliance circles. Think CSI: Crime Scene Investigation. Essentially, an adviser should conduct some type of transactional or quality control tests that will assist the adviser in determining whether its activities are consistent with … Continued

Personal Liability and SEC Enforcement

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Lest you think the SEC is not serious about holding individuals personally liable, here is an excerpt from a recent speech by Chairperson White: Individual Liability:  Any discussion of strong enforcement tools must include a discussion of our priority of … Continued

SEC Warns on CCO Outsourcing

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The SEC recently conducted examinations of around 20 SEC-registered investment advisers and investment companies that outsourced their CCOs to unaffiliated third parties. The general takeaway is that outsourced CCOs sometimes were not knowledgeable about a firm’s business practices, did not have access to … Continued

The Need for a Risk Assessment

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The SEC has made it clear time and time again that the first step toward developing strong written policies and procedures is for an investment adviser to identify all areas that create risk exposure or the potential for risk exposure. Accordingly, … Continued

An Ounce of (Compliance) Prevention

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The enforcement staff gives credit to registrants that demonstrate effective compliance programs and a genuine commitment to ethical principles.  Advisers should focus on persuading the enforcement staff of the quality and depth of a firm’s compliance culture and its record … Continued

The Compliance Manifesto

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In a recent speech an SEC official said that the presence of robust, effective compliance programs would allow companies to reap significant credit in their dealings with regulators. He spoke about the ways the SEC supports compliance and ethics programs. … Continued