The SEC’s most recent risk alert, “Observations from Investment Adviser Examinations Relating to Electronic Messaging,” issued on December 14, 2019, focuses on the use and maintenance of electronic communications for business purposes. The purpose of the alert is to remind advisers of their obligations related to personal use of electronic messaging and the requirements for … Continued

Well ahead of the New Year, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2019 examination priorities. In keeping with OCIE’s four “pillars” of promoting compliance, preventing fraud, identifying and monitoring risk, and informing policy, the Dec. 20 release provides a preview of key areas where OCIE intends to focus its limited … Continued

Our annual year-end review covers investment adviser compliance highlights from 2018, and makes 2019 predictions. We will highlight enforcement actions and SEC risk alerts for retail advisers, private fund managers, and institutional wealth managers. Using these as road markers, our predictions are designed to lead reasonable and effective compliance program development. Evaluate 2018 Compliance and … Continued

From the top of the world, it’s amazing what you can see.  I recently had the opportunity to travel to the United Arab Emirates to speak in Dubai at the 7th Edition of the Alternative Investment Management Summit. While I was there, I took a few moments to ride to the top of the Burj … Continued

Earlier this year when the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2018 examination priorities, OCIE stated that a core priority was to protect retail investors, including seniors and individuals saving for retirement. OCIE is now continuing this effort by focusing on mutual funds and exchanged-traded funds (together, the “Funds”) as the … Continued