Please note: This page is displaying archived or unstyled content from a previous version of the Ascendant Compliance website. Images found below are unlikely to display, you may encounter broken links & missing downloads and general layout might be broken.
Cyber Crimes – Don’t Forget to File that SAR!
Stopping, or even slowing, the proliferation of cyber-event related criminal activities remains a chief goal in the broker-dealer and investment advisory communities. As pointed out in a 2016 advisory released by the Financial Crimes Enforcement Network (“FinCen”), “Cyber-events targeting financial institutions often constitute criminal activity and can serve as means to commit a wide range of … Continued
DOL Rule Extension to Overlap with SEC Consideration of Fiduciary Standards
Following the Department of Labor’s November 27, 2017 announcement of an 18-month extension to the existing Fiduciary Rule transition period, the industry will enter a period of further study for proper standards for disclosure or elimination of conflicted compensation arrangements. That’s a mouthful right there. The Obama administration’s March 31, 2017 implementation of various new prohibited … Continued
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
Subscribe to the Ascendant Compliance email list for the latest compliance resources, conferences, ComplianceCasts™, and more.