Planning for the Annual Review and Reporting
- Who Conducts and How to Conduct the Annual Review
- Planning and Documenting the Annual Review
- Testing the Adequacy and Effectiveness of Policies and Procedures
- Reporting Annual Review Findings
- Responding to Issues Identified by the Annual Review
- Common Deficiencies with Annual Reviews
Fill in the form below
How Do You Supervise for SEC Pay-to-Play Violations?
If you wanted more information about the contours of the SEC’s Pay-to-Play Rule, or how the SEC may enforce it, three recent Settlement Orders against large investment advisers for “over de minimis” political contributions provide some insight regarding one of the prohibitions: Contributions by Covered Associates to certain Government Officials over the specified Exception amount (capitalized words are terms in the … Continued
Do your Fund Documents Clearly Disclose Receipt of Accelerated Monitoring Fees?
Somewhat more reminiscent of the broken-windows enforcement era, two affiliated private equity advisers managing billions settled with the SEC on charges that they failed to make pre-commitment disclosures in fund governing documents related to accelerated fees received from portfolio companies. Interestingly, according to the Settlement Order, the advisers had made some disclosures in fund documents … Continued
With New Risk Alert, SEC Doubles Down on Best Execution
On July 11, 2018, the SEC issued a Risk Alert outlining commonly found compliance issues related to best execution by investment advisers. Advisers have an obligation to seek best execution of client transactions, taking into consideration quantitative factors such as execution quality and commission rate, as well as more qualitative factors such as the value … Continued
The Cost of Compliance: Understanding and Leveraging Resources
For compliance officers, obtaining the necessary tools and resources to build an effective compliance program can be costly and difficult to implement. How do you distinguish the best in class, the most cost-efficient and effective for use in your program? In this ComplianceCast, speakers David Porteous of Faegre Baker Daniels and Korrine Kohm of Ascendant … Continued
California Privacy Law Brings GDPR-Lite to the U.S.
New Act Will Give Consumers Rights to Access and Delete Their Data In what has become an ongoing race among states to have the toughest privacy regulation in the U.S., California has jumped to the front. On June 28, 2018, California’s legislature unanimously passed a privacy bill that was later signed by Governor Jerry Brown, … Continued
Subscribe to the Ascendant Compliance email list for the latest compliance resources, conferences, ComplianceCasts™, and more.