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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OCIE Examined 15% of RIAs in 2017

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 … Continued

Ascendant’s Adam DiPaolo Discusses Hypothetical & Model Performance Marketing Pitfalls

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 the … Continued

SEC’s Exam Priorities Offer Insight Into National Exam Program

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: … Continued

SEC Updates: ICO Gatekeeper Standards, SEC/CFTC Swap Rules

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, they … 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.