Upcoming ComplianceCasts™

Custody – Get It Right: Just in Time for Your Annual Updating Amendment!

Broadcast Date: Wednesday, Feb 28 at 1pm ET

The SEC’s Custody Rule and its application to registered investment advisers is complicated and often misunderstood, and custody issues remain among the most common deficiencies cited during SEC exams.

Join this important ComplianceCast to understand the key elements of the Custody Rule; identify available exceptions to certain requirements of the Custody Rule based on industry and SEC guidance; and learn how to identify accounts over which your firm has custody for purposes of Form ADV.

Covering topics and questions regarding:

  • SLOAs (must be included in response to Item 9 of Form ADV after 10/01/2017)
  • Third Party wires
  • Third Party checks
  • First person transfers
  • Client Custodian and IMA contracts
  • Documentation
  • and more
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Insurance Considerations for Investment Advisers

Broadcast Date: Thursday, Mar 22 at 2pm ET

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 discussion of:

  • Types of Coverage (E&O, D&O, Cyber Policies) – What Do They Protect?
  • ERISA 3(38) Bonding and Fiduciary Considerations
  • Determining How Much Coverage You Need Based Upon Your Firm’s Size and Business Strategy
  • Underwriting and Costs
  • What Happens When You Need to Use Your Policy
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Recent ComplianceCasts™

Recent ComplianceCast™ Minutes


ComplianceCasts™ are the property of Ascendant Compliance Management, Inc. (“Ascendant”) and/or may not be reproduced or redistributed in any form without the express written consent of Ascendant. ComplianceCasts™ are provided for educational purposes only, and are not intended to be and cannot be construed to be financial or legal advice. Ascendant is not a law firm and does not provide legal advice. Adherence to any recommendation does not imply compliance with any applicable law, regulation, or guidance. All facts and matters stated herein should be independently verified.

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OCIE Examined 15% of RIAs in 2017

In 2017, the SEC examined 2,114 investment advisers, approximately 15 percent of the 14,000+ registered investment advisers, the SEC confirmed in its Fiscal Year 2019 Congressional Budget Justification Annual Performance Plan. In the same report, the SEC said the staff will continue to improve its efforts of RIAs, noting that nearly 35 percent of all … Continued

Ascendant’s Adam DiPaolo Discusses Hypothetical & Model Performance Marketing Pitfalls

A Jan. 12 article in HFMCompliance titled “Best practice for hedge funds using hypothetical and model performance” outlines best practices for hedge fund managers when using hypothetical performance or model data in marketing efforts, and how managers relying on such data can avoid enforcement actions. Adam DiPaolo, Senior Consultant in Ascendant’s Private Funds group, is quoted in the … 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

SEC Updates: ICO Gatekeeper Standards, SEC/CFTC Swap Rules

SEC Chairman Jay Clayton had some stern advice for market professionals, especially gatekeepers, who he said need to act responsibly and hold themselves to high standards. Speaking via videoconference during Securities Regulation Institute’s recent annual conference, he said, “To be blunt, from what I have seen recently, particularly in the initial coin offering (“ICO”) space, they … 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.