SEC OCIE Issues 2019 Examination Priorities

Well ahead of the New Year, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2019 examination priorities. In keeping with OCIE’s four “pillars” of promoting compliance, preventing fraud, identifying and monitoring risk, and informing policy, the Dec. 20 release provides a preview of key areas where OCIE intends to focus its limited … Continued

SEC Retail Investor Focus Turns Towards Registered Investment Companies

Earlier this year when the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2018 examination priorities, OCIE stated that a core priority was to protect retail investors, including seniors and individuals saving for retirement. OCIE is now continuing this effort by focusing on mutual funds and exchanged-traded funds (together, the “Funds”) as the … Continued

SEC Cyber Sweep Highlights Areas In Need of Improvement

The results of the SEC’s second cybersecurity sweep examinations are in, and they paint a picture of an industry that has come to grips with the need to address cybersecurity risk, but where the canvas is incomplete in many respects.

SEC Releases 2017 Examination Priorities

The SEC’s Office of Compliance and Examinations (“OCIE”) released its Examination Priorities for 2017 with a focus on “certain practices, products, and services that OCIE perceives to present potentially heightened risk to investors and/or the integrity of the U.S. capital markets.”

The Cybersecurity Sweep Exam Results and What It Means for Compliance

In this ComplianceCasts Minute, Ascendant consultants Jackie Hallihan and Eugenie Warner discuss the results of the SEC’s Cybersecurity Sweep Exam. Covering how firms identify cybersecurity risks, establish cybersecurity policies, procedures and oversight processes and more, the cybersecurity sweep is just the beginning as OCIE’s 2015 Examination Priorities indicate that cybersecurity will again be a risk … Continued

Highlights Of Andrew Bowden’s Speech: Spreading Sunshine In Private Equity

Andrew Bowden, Director of the Office of Compliance Inspections and Examinations, recently shared insights from 2 years of private equity adviser examinations, and our consultants now share a brief recap of his May 6th speech. Hear the highlights of over 150 examinations, the summary of violations, problems, and concerns surrounding fees, expenses, valuation, and marketing. … 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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