Companies struggling with Word, Excel and other traditional applications to support compliance functions, often lack guidance when evaluating tailored software as a service.
Our main focus is on the benefits of modern software, practical functionality, and tailored content for improving business practices. In the context of compliance, these business practices are maintaining current and adaptive policies and procedures, relating these policies to risk inventories and controls, and testing the utility of such controls via collaborative checklists, with appropriate internal resources and marginal incremental costs per change.
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Practical IT Change Management, the CCO’s Best Friend: Utilizing Change Management to Evidence Monitoring
Social Engineering & Ransomware
Friend-ing Social Media: Considerations for Investment Advisers Use of Social Media Networks
Where, When and How to Make a Disciplinary Disclosure in Regulatory Filings
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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