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

CCO Liability – Line in the Sand

The defense of a CCO's reputation against liability claims costs significant money, and adds up whether you did something wrong or not, sparking the potential need for an individual liability policy.

Why Care About Ethics?

A 2013 speech by Stephen L. Cohen, Associate Director of Enforcement of the SEC, highlighted the importance of corporate compliance and ethics. Importantly, the speech set out to explain how a good, effective compliance program can often help a firm mitigate their risk ranking with the SEC’s National Examination Program. So in other words, being … Continued

Latest Content

Evolution of Fiduciary Rules Begins to Take Shape in SEC

On April 18, 2018, the SEC voted to propose several new rules and reforms related to fiduciary standards. The package intends to raise and clarify standards of conduct for broker-dealers and investment advisers, and to provide clarity regarding fees, conflicts and other material matters. It also aims to ensure that the standards can be understood … Continued

Insurance Considerations for Investment Advisers

How much coverage is enough? What types of insurance policies do you need? Whether you are starting an investment advisory practice, launching a new line of business, or reevaluating your existing risks, there are critical questions to ask to make sure you understand the various ways to protect your firm. Join us for a practical … Continued

Fifth Circuit Weighs In on DOL Fiduciary Rule

A panel of the U.S. Court of Appeals for the Fifth Circuit has vacated the Department of Labor’s Fiduciary Rule. In a 2-1 split, the Fifth Circuit’s decision overrules a Dallas District Court’s decision, which had previously upheld the rule. Unfortunately, the decision does little to settle the fate of the beleaguered rule. Although it … Continued

SEC Proposes Amending Investment Company Liquidity Disclosures in Forms N-PORT and N-1A

On March 14, 2018, the Securities and Exchange Commission (“SEC”) proposed amendments to the mutual fund liquidity-related disclosure requirements. Specifically, the proposal: Adds a new requirement to “briefly discuss the operation and effectiveness of the Fund’s liquidity risk management program during the most recently completed fiscal year” in the Fund’s Management Discussion of Fund Performance … Continued

Paradigm Shift in SEC Exams, Benefits of a Mock Exam

For investment advisers currently going through an SEC exam, the process likely bears little resemblance to exams of old. Call it the new normal, a paradigm shift, or simply the effects of the SEC having to do more with less, but anecdotal evidence among those now experiencing the exam process suggests some interesting new trends. … Continued

Mailing List

Subscribe to the Ascendant Compliance email list for the latest compliance resources, conferences, ComplianceCasts™, and more.

Loading form...

Contact Us

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.