Standards of Business Conduct: Personal Trading and Beyond

One of the most important assets a firm can possess is a sterling reputation, and maintaining such a reputation involves proactive attention. While most firms address standards of business conduct in their Codes of Ethics, it’s important to periodically reassess and update them. By incorporating technology, firms can mitigate reputational risk and maximize efficiency throughout their organization. Please join us for a practical discussion of:

  • Evolving standards of business conduct
  • How to incorporate technology into your Code of Ethics
  • Methods of testing and improving controls

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When Policies, Procedures and Testing Protocols Aren’t Enough…

The Compliance Program Rule continues to be a powerful tool for SEC enforcement, recently used by the SEC to address trading away in wrap accounts, misappropriation of retail client assets, and the misuse of an omnibus account. Advisory firms had written policies and procedures and testing protocols, but they were not good enough; are yours? … Continued

The Compliance Professionals Guide to Effective Trade Desk Monitoring

Global regulators continue to enhance their ability to monitor the activities of market participants through a combination of new rules, filing requirements, and upgrades to surveillance technologies. As a result, many market participants, including both buy-and sell-side firms, need to re-assess how they currently monitor the trading desk, and whether new policies and procedures are … Continued

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

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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.