Blog – Ascendant Compliance https://www.ascendantcompliance.com Ascendant Compliance Management is a leader in the compliance and regulatory services industry, offering personalized, comprehensive compliance services for firms in the U.S. and abroad. Fri, 23 Feb 2018 10:39:18 +0000 en-US hourly 1 OCIE Examined 15% of RIAs in 2017 https://www.ascendantcompliance.com/blogs/ocie-examiners-examined-15-of-rias-in-2017/ Thu, 15 Feb 2018 22:02:51 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3432 Continued]]> In 2017, the SEC examined 2,114 investment advisers, approximately 15 percent of the 14,000+ registered investment advisers, the SEC confirmed in its Fiscal Year 2019 Congressional Budget Justification Annual Performance Plan. In the same report, the SEC said the staff will continue to improve its efforts of RIAs, noting that nearly 35 percent of all registered investment advisers have never been...

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Ascendant’s Adam DiPaolo Discusses Hypothetical & Model Performance Marketing Pitfalls https://www.ascendantcompliance.com/blogs/ascendants-adam-dipaolo-discusses-hypothetical-model-performance-marketing-pitfalls/ Wed, 14 Feb 2018 22:14:27 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3414 Continued]]> Adam DiPaolo A Jan. 12 article in HFMCompliance titled “Best practice for hedge funds using hypothetical and model performance” outlines best practices for hedge fund managers when using hypothetical performance or model data in marketing efforts, and how managers relying on such data can avoid enforcement actions. Adam DiPaolo, Senior Consultant in Ascendant’s Private Funds group, is quoted in...

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SEC’s Exam Priorities Offer Insight Into National Exam Program https://www.ascendantcompliance.com/blogs/secs-exam-priorities-offer-insight-into-national-exam-program/ Wed, 14 Feb 2018 15:00:32 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3403 Continued]]> On February 7, 2018, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued their 2018 Examination Priorities (see Ascendant’s summary here). In addition to defining their examination priorities for the year, the OCIE staff offered some insight into the National Exam Program.  Specifically, they defined the following five principles in executing their exam priorities:...

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SEC Updates: ICO Gatekeeper Standards, SEC/CFTC Swap Rules https://www.ascendantcompliance.com/blogs/sec-updates-ico-gatekeeper-standards-sec-cftc-swap-rules/ Tue, 13 Feb 2018 15:59:09 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3394 Continued]]> SEC Chairman Jay Clayton had some stern advice for market professionals, especially gatekeepers, who he said need to act responsibly and hold themselves to high standards. Speaking via videoconference during Securities Regulation Institute’s recent annual conference, he said, “To be blunt, from what I have seen recently, particularly in the initial coin offering (“ICO”) space...

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2018 SEC Exam Priorities: What You Need to Know https://www.ascendantcompliance.com/blogs/2018-sec-exam-priorities-what-you-need-to-know/ Fri, 09 Feb 2018 15:59:18 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3385 On February 7, 2018, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released its Examination Priorities for 2018. This is the sixth year that OCIE staff has issued their priorities, which provide transparency into their thinking and guidance for advisers reviewing their compliance programs. The priorities are organized around five themes: protecting retail investors...

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The Problem with Buying Off-the-Shelf: It May Not Fit! https://www.ascendantcompliance.com/blogs/the-problem-with-buying-off-the-shelf-it-may-not-fit/ Wed, 07 Feb 2018 21:13:55 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3370 The Fort Worth, Texas, Regional Office (“FWRO”) of the SEC recently named the failure to sufficiently tailor off-the-shelf compliance programs as one of its most cited deficiencies during regulatory exams in 2017. According to the FWRO, such deficiencies were present in nearly half of all examinations conducted by them. The news came during a first-of-its-kind call directly between the FWRO and...

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U.S. Advisers Getting Serious About Fast-Approaching GDPR Deadline https://www.ascendantcompliance.com/blogs/u-s-advisers-getting-serious-about-fast-approaching-gdpr-deadline/ Thu, 01 Feb 2018 20:30:26 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3328 For over a year, May 25, 2018 has been circled on the calendars of many chief compliance officers and chief technology officers at U.S.-based investment advisers and asset managers with a European presence or European investors. For others, the quickly approaching date may be coming as a surprise as they grapple with how to tackle yet another broad regulation with significant financial...

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Ascendant Shortlisted for Two Global Compliance Awards https://www.ascendantcompliance.com/blogs/ascendant-shortlisted-for-two-global-compliance-awards/ Wed, 31 Jan 2018 21:50:39 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3309 Continued]]> Ascendant is proud to have several team members honored by being shortlisted for C5’s 2018 Women in Compliance Awards. The international awards highlight the top achievers and teams in the compliance industry, embodying the efforts of an evolving and dynamic profession. Jackie Hallihan Ascendant’s Executive Director Jacqueline Hallihan has been shortlisted for the Lifetime Achievement Award for...

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SEC Delays Form N-PORT Submission Requirements https://www.ascendantcompliance.com/blogs/sec-delays-form-n-port-submission-requirements/ Wed, 20 Dec 2017 15:57:43 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3219 Continued]]> On Friday, December 8, 2017, the SEC issued a Temporary Rule that provides a nine-month delay of the filing dates for certain registered investment companies to submit data using the new Form N-PORT via the EDGAR system. The SEC delayed the initial reporting requirement for Form N-PORT, giving the agency time to review data security for EDGAR and its other systems. For larger fund groups with net...

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Transparency Spreads to FINRA Exam Findings https://www.ascendantcompliance.com/blogs/transparency-spreads-to-finra-exam-findings/ Thu, 14 Dec 2017 22:00:07 +0000 https://www.ascendantcompliance.com/?post_type=blogs&p=3202 Continued]]> On December 6, 2017, FINRA did something it has never done before: It released a summary report of its examination findings. While FINRA has annually released an examination priorities letter, this report is a first for examination findings. Why now? Credit FINRA’s new president and CEO, Robert W. Cook..  Since joining FINRA in 2016, Cook has been meeting with member firms and listening to their...

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