SEC Exam Priorities – Cybersecurity

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As part of its 2015 exam priorities, the Office of Compliance Inspections and Examinations (OCIE) cited their continued focus on cybersecurity issues. If you remember back, in April of 2014 OCIE issued a Risk Alert detailing its initiative to assess cybersecurity preparedness. … Continued

SEC Exam Priorities 2015

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The SEC today announced its Office of Compliance Inspections and Examinations’ (commonly known as OCIE) priorities for 2015 which focus on three areas: protecting retail investors, especially those saving for or in retirement; assessing market-wide risks; and using data analytics to … Continued

Alert – Social Media

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A copy of the SEC Social Media Document Request Letter is reprinted below. Perhaps it is time to revisit your social media policies and procedures.  …………………. DOCUMENTS TO BE PRODUCED Please produce the following documents within Adviser’s possession or custody … Continued

SEC Exam Initiative

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Dear Compliance Professional, The SEC today announced that its Office of Compliance Inspections and Examinations (OCIE) is launching an initiative directed at investment advisers that have never been examined, focusing on those that have been registered with the SEC for … Continued

SEC Exam Priorities – Update

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Dear Compliance Professional, As part of its 2014 Exam priorities, the SEC announced that the “staff will utilize a number of strategies to conduct focused, risk-based examinations of the adviser population that has been registered for more than three years … Continued

SEC Guidance on Reporting Financial Abuse of Older Adults

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Seven federal regulatory agencies today issued guidance to clarify that the privacy provisions of the Gramm-Leach-Bliley Act generally permit financial institutions to report suspected elder financial abuse to appropriate authorities. The Gramm-Leach-Bliley Act generally requires that a financial institution notify … Continued

SEC Risk Alert – Custody

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The alert by the SEC’s Office of Compliance Inspections and Examinations (OCIE) comes after a review of recent examinations where significant deficiencies were identified showed custody-related issues in about one-third of the firms examined. The advisers’ deficiencies included: Failure to … Continued

Compliance Alert – SEC Exam Priorities

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Dear Compliance Professional,   The National Examination Program (NEP) of the SEC’s Office of Compliance Inspections and Examinations recently released its examination priorities for 2013. The NEP release addresses both market-wide priorities and priorities for each of the NEP’s four … Continued

Compliance Alert! Compliance Resolutions (Part 2)

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Dear Compliance Professional, Continuing on with our New Year’s compliance resolutions. . . Conduct a Risk Assessment It is clear from the recent trend of SEC examinations that regulators are sanctioning advisory firms that do not conduct an annual risk … Continued

Compliance Alert! Compliance Resolutions (Part 1)

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Dear Compliance Professional, As we start the new year, I think it appropriate that investment advisers add a few compliance-related resolutions to go along with the more typical “eat healthy, exercise more” resolutions we usually break by the second week … Continued

Compliance Alert! Wire Fraud Scam

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Dear Compliance Professional, We have just been notified by one of our clients of a wire fraud scam and wanted to bring it to your immediate attention. A cyber criminal created a fake client email message in an attempt to … Continued

Compliance Alert! Social Media

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Dear Compliance Professional, Rarely do we see the SEC Office of Compliance Inspections and Examinations issue a National Examination Risk Alert. So when they do, we pay particular attention. Last week, OCIE issued just such a National Examination Risk Alert … Continued

Compliance Alert! Data Security

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Dear Compliance Professional, The protection of a client’s non-public personal information is one of the most important tasks entrusted to an investment adviser. Unfortunately, it is also one of the most vexing issues confronting compliance professionals. Any time an adviser … Continued

Compliance Alert! Special Concerns

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Dear Compliance Professional, The Compliance Alert below was originally sent out in 2008. Unfortunately, recent market events make the subject matter relevant once again. We will also be sending out other pertinent Compliance Alerts from 2008-2009. Background The purpose of … Continued

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