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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Ascendant’s Jason Morton to Speak on RegTech at Strata Data Conference

Alongside technology experts from American Express, Credit Suisse and CIBC, Ascendant’s Jason Morton will speak on developments in regulatory technology at the ‘Fintech Data Day’ at the annual Strata Data Conference on September 26, 2017 in New York. The Strata Data Conference is an annual conference for technology and business professionals who are seeking innovative … Continued

Hurricane Season: How Does your BCM Program Stack Up?

As Hurricane Harvey touches down on U.S. soil and we hope for the safety of the millions in its path, we encourage all firms, even those outside Harvey’s path of flooding and damaging winds, to consider their BCM readiness for such an event. Business Continuity Plans are designed to ensure firms have conducted sufficient advance preparation so … Continued

Surprise, Surprise: SEC Conducting Unannounced Exams

The Boston Regional Office of the SEC has recently conducted roughly 20 unannounced visits to registered investment advisers in the region. This fact, confirmed during the recent meeting of the New England Broker-Dealer and Investment Adviser Association (NEBDIAA), is in keeping with the SEC’s renewed focus on a more robust examination program. While onsite, the … Continued

One Phish, Two Phish, Red Phish, Blue Phish: How to Detect and Mitigate Social Engineering and Ransomware Techniques

Ransomware attacks like WannaCry and NotPetya are increasing in both frequency and damage, routinely making headline news with their abilities to bring down networks of established companies. Yet these cyberattacks typically start by compromising the weakest point in your security chain – people – through simple or complex phishing techniques before spreading to other parts … Continued

DOL Fiduciary Rule Transition Period Extension to 2019 Requested

The Secretary of Labor, Alexander Acosta, made a court filing on August 9 requesting the Transition Period and Delay of Applicability for the Department of Labor Fiduciary Rule be extended from January 1, 2018 to July 1, 2019. This court filing included extending the deadlines for the following Prohibited Contract Exemptions: Best Interest Contract Exemption … 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.