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Firms Encouraged Not to Overlook Oct. 1 Books and Records Changes
While changes to Form ADV on October 1, 2017 have been well-publicized, we encourage firms not to overlook the other changes to Books and Records requirements put forth in the SEC’s final rule release, effective October 1, 2017. The changes to the Rule relate to the retention of documents regarding the calculation of performance data. Rule … Continued
SEC Offers Regulatory Relief to Advisers Affected by Hurricanes
On September 28, 2017, the SEC provided regulatory relief to individuals and entities subject to the ’33 Act, ’34 Act and ’40 Act who were affected by Hurricanes Harvey, Irma or Maria. The relief came in the form of conditional exemptions from certain requirements. The hurricanes, which struck between August and September of 2017, devastated … Continued
SEC Discloses Cybersecurity Breach That May Have Led to Insider Trading
The determination of hackers to exploit existing cybersecurity vulnerabilities of government agencies and businesses shot to the forefront again last Wednesday, when SEC Chair Jay Clayton revealed that the commission’s EDGAR database had been hacked in 2016 through a software vulnerability in the test filing component of the system. According to Clayton, the breach was … Continued
Ethics: Building a More Ethical Workforce
How to make ethics part of your Firm’s Compliance Culture Where does the requirement to act ethically come from? Dealing with Ethical Dilemmas 2016 SEC Enforcement Cases that pertain to Ethics
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