Happy 10 Year Anniversary To The Compliance Program Rule

How Do Your Policies & Procedures Measure Up?
The SEC adopted Rule 206(4)-7 in 2004 under the Advisers Act which required each investment adviser registered with the Commission to adopt and implement written policies and procedures reasonably designed to prevent violation of the federal securities laws, review those policies and procedures annually for their adequacy and the effectiveness of their implementation, and designate a chief compliance officer to be responsible for administering the policies and procedures. How has your manual evolved in those 10 years since the rule was effected?

  • Discussion of recent policies adopted (e.g., ITPP)
  • Building an “effective compliance manual”
  • Policies beyond the scope of the Advisers Act (FCPA, DOL related, etc.)
  • Evolution of the CCO position

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Schedule 13D/13F Clarity on ETF Issues

Do I need to file a 13D or 13G if my client accounts hold in excess of 5% of an ETF? Generally, no. The SEC has granted no-action relief to ETFs with respect to compliance with Section 13(d) of the Securities Exchange Act. Section 13(d) was designed to require disclosure when holders begin to accumulate … Continued

New Remedy Coming for SEC’s Custody Rule?

The SEC’s Custody Rule continues to be a common source of confusion and a landmine for noncompliance. Custodial paperwork has caused huge headaches for investment advisers, who are not a party to the agreement and may not even have a copy of the custodial new account paperwork. The issue with existing guidance is that it … Continued

SEC Issues MiFID II No-Action Relief

Some industry anxiety was assuaged on October 26 with three no-action letters that offer relief for some US regulated broker-dealers and investment advisers regarding European MiFID II regulations. The letters followed consultation with the European authorities, and are designed to address concerns that investors could lose access to valuable research. MiFID II is a series of regulations … Continued

Regulatory Changes Impacting RICs and Service Providers

A year ago, the SEC adopted Investment Company Reporting Modernization Rules and Forms, as well as rules pertaining to liquidity risk management programs and swing pricing. New forms N-Port and N-Cen along with amendments to Regulation S-X significantly change the current reporting regime for most registered investment companies (RICs) because they require more comprehensive disclosure and … Continued

Publicly Available Information Heightens Need for Cybersecurity Vigilance

For any business, “ports” that allow for communication generally need to be open (for example, ports 80 and 443 for websites, and port 500 for VPN access). While most of these ports allow you to engage in critical functions, there are often ports that remain open despite being unneeded or unused. These available ports present … Continued

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Ascendant works together with clients to identify and assess critical needs through customized plans. If you need assistance with compliance functions, regulatory services, cybersecurity or technology tools, we’d love to speak with you.