How to Be a Wildly Effective Compliance Officer

Being a Compliance Officer is no easy task. Administering a compliance program, implementing controls to help protect clients and the firm, and staying on top of new regulations is only part of the job. Compliance Officers are also expected to be flexible and pro-business. So how do you do it all? How can you be … Continued

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

SEC’s Exam Priorities Offer Insight Into National Exam Program

On February 7, 2018, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued their 2018 Examination Priorities (see Ascendant’s summary here). In addition to defining their examination priorities for the year, the OCIE staff offered some insight into the National Exam Program.  Specifically, they defined the following five principles in executing their exam priorities: … Continued

Surprise, Surprise: SEC Conducting Unannounced Exams

The Boston Regional Office of the SEC has recently conducted roughly 20 unannounced visits to registered investment advisers in the region. This fact, confirmed during the recent meeting of the New England Broker-Dealer and Investment Adviser Association (NEBDIAA), is in keeping with the SEC’s renewed focus on a more robust examination program. While onsite, the … Continued

ComplianceCast: Advertising & Marketing Compliance

Have questions on Advertising and Marketing Compliance? Ascendant’s Samantha Addonizio and Peter Guarino take a look at The Rules, Hot Topics & Reviewing Tips for compliance professionals. This complimentary ComplianceCast covers the following topics: Investment Adviser Advertising Rules and No-Action Guidance Performance Advertising – General Requirements, Model Performance & Hypothetical Back-tested Performance Use of Third-Party Performance … Continued

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Takeaways and Tips Related to SEC Risk Alert on Regulation S-P

On April 16, 2019, the SEC released a Risk Alert providing a list of compliance issues related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment advisers and broker-dealers. As with other risk alerts, these were deficiencies noted by OCIE in regulatory examinations. Though the deficiencies were fairly common … Continued

How to Be a Wildly Effective Compliance Officer

Being a Compliance Officer is no easy task. Administering a compliance program, implementing controls to help protect clients and the firm, and staying on top of new regulations is only part of the job. Compliance Officers are also expected to be flexible and pro-business. So how do you do it all? How can you be … Continued

Mitigating the Risk of Insider Trading

One of the biggest risks affecting investment advisers is the potential that material non-public information (“MNPI”) may be misused, leading to a charge of insider trading. Advisers should implement controls to mitigate these risks. Steven Stone of Morgan, Lewis & Bockius, LLP, Salvatore Cincinelli of the FBI and David Chaves of Tone at the Top … Continued

Compliance 2.0 – Being a Strategic Partner in Your Firm

Compliance as a profession continues to evolve. With Enron, Bernie Madoff and numerous other failures paving the way for rulemaking across industries and nations, the days of drawing a short straw, getting drafted into a compliance role and operating in isolation outside of the business are – or should be – ancient history. Since the … Continued

Big Data Part III: Preparing for the Future of Global Regulatory Governance

United States and European Union reporting requirements imposed on investment managers have exploded since the Global Financial Crisis and, with the imminent arrival of SFTR in Europe, it seems poised to expand again. The challenge of reporting trades, transactions and contracts in multiple jurisdictions requires firms to embrace technology as regulators continue to look to … 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.