Key No-Action Letters

A Step Beyond the Statutes & Rules

  • Gross& Net Performance Reporting
  • Reprints & Testimonials
  • Assignment of Advisory Agreements
  • Private Offering Guidance (Sample Letters Include Clover Capital, Stalker, Dalbar, Unibanco & Lamp Technologies)

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SEC’s Latest Risk Alert Focuses on Electronic Communications

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

SEC OCIE Issues 2019 Examination Priorities

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

Highlights of 2018: Predictions for 2019

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

A New View of How Technology Will Change the Emerging Crytpo-Economy

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

SEC Retail Investor Focus Turns Towards Registered Investment Companies

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

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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.