When investment advisers use the cloud, they are making a conscious, informed decision to outsource tasks to vendors who may have particular expertise or infrastructure in place to handle such tasks. From hosted email archiving to compliance reporting, and from hosted backups to client communication portals, moving data to the cloud can help many firms address business needs while enabling them to focus more on their core business – providing investment advice. However, the Securities and Exchange Commission has made it clear that while financial professionals can outsource processes, they cannot delegate the ultimate responsibility for the performance of those functions. After all, it is the investment adviser who is in the trusted position of a fiduciary with respect to the adviser’s clients.
Fill in the form below
Past Conference Speaker Inspiration for The Rock’s Next Blockbuster
If you attended Ascendant’s 2016 San Diego conference, you will no doubt remember our outstanding keynote speaker, Jeff Glasbrenner. Jeff is a below-the-knee amputee who was fresh off becoming the first American amputee ever to scale Mount Everest. In San Diego, he spoke about turning challenges into triumphs, and about succeeding in the face of … Continued
Relief at Last – New Guidance on Inadvertent Custody
The SEC quietly provided additional guidance to the industry about inadvertent custody in supplemental responses to the Custody Rule FAQs. In Question II.11 and II.12, the SEC stated that it would not recommend enforcement against an adviser that does not have a copy of a client’s custodial agreement, and does not know or have reason … Continued
Advisers Beware: FBI “Operation WireWire” Shows Firms Increasingly Being Targeted Using SEC Filings
Ascendant has observed more and more investment advisers falling victim to Business Email Compromise, or “BEC” schemes over the past year. Unfortunately, they are in good company, as the trend is consistent with a worldwide increase in such attacks by increasingly skilled hacker networks around the world. On June 10, 2018, the FBI announced in … Continued
Deputy Attorney General Rod Rosenstein Discusses Compliance Program Effectiveness
The embattled U.S. Deputy Attorney General Rod Rosenstein recently spoke to compliance pros at the 2018 Annual Conference for Compliance and Risk Professionals. Bulleted below are some of the statements from his keynote speech, which evidence the view from near the top of the Department of Justice: As to what it means to have a culture … Continued
Cayman Islands Update AML Regulations for Private Equity
The Cayman Islands has further bolstered its anti-money laundering (“AML”) and countering of terrorist financing (“CTF”) rules. The new AML/CTF rules become effective on May 31, 2018 and will affect, among others, unregulated investment entities—such as private equity firms—domiciled in the Cayman Islands. The deadline to appoint AML officers, however, is September 30, 2018 for … Continued
Subscribe to the Ascendant Compliance email list for the latest compliance resources, conferences, ComplianceCasts™, and more.