Business Continuity Redux: How the Perfect Storm Provided Regulators with the Perfect Opportunity

The breadth and destructive force of Hurricane Sandy, which in October 2012 spread across 15 states as the largest Atlantic hurricane on record, tested the financial industry’s best-laid plans for business continuity management (BCM). Regulatory authorities, such as the Securities and Exchange Commission (SEC), the Financial System Regulatory Authority (FINRA), and the Commodity Futures Trading Commission, used this event to re-examine, re-emphasize, and re-educate the financial base concerning common weaknesses and lessons learned. And beyond the regulatory compliance concerns, many investment advisors learned how a disaster could severely challenge their service to clients and the stability of their businesses.

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Advertising Issues: SEC and GIPS Performance in the Private Fund Space

Over a year ago, OCIE released the Risk Alert, “The Most Frequent Advertising Rule Compliance Issues Identified in OCIE Examinations of Investment Advisers.” While the alert highlighted several areas where performance advertising is involved, our recent CSS/Ascendant conference panelists in a session entitled “Best Practices for SEC and GIPS Performance in the Private Fund Space” … Continued

Placing Ethics and Compliance in the Foreground of Business Decision-Making

Thinking about how to make ethics and compliance part of a business’s decision-making can prove to be challenging. By nature, compliance professionals are often results-oriented, focusing on a binary end-result; either you are in compliance, or you are not. That focus is important, but emphasizing process is also vital, John Walsh, Partner at Eversheds Sutherland … Continued

What Am I Looking At? Making Sense of Your Cyber Testing Reports

It’s no surprise that Compliance and IT do not speak the same language. Compliance staff often speak in terms of regulations and policies, whereas bits and bytes are the language of IT staff. This distinction is clear when it comes to cybersecurity risk management, as the compliance and IT audiences are looking for different takeaways … Continued

It Takes a Village – Preparing for a Regulatory Exam

Advanced planning for a regulatory exam remains a vital step in ensuring the compliance team is prepared when the exam teams comes knocking. At the recent Ascendant/CSS fall conference in San Diego, Allison Fraser moderated the conference’s capstone session on the topic, joined by Bryan Bennett, the Associate Regional Director in the examination program in … Continued

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