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Many chief compliance officers struggle every year with preparing the annual review required under Advisers Act Rule 206(4)-7. To help you out, here’s our guide to writing your annual...
LESSONS LEARNED - SEC Rules that Investors Win in Battle over Inconsistent Documentation. A private fund advisor learned that the details matter in this case brought by t...
Collaboration between compliance and operations is key.
For Investment Advisers and Broker-Dealers DOL issues Cybersecurity Guidance. On April 14, 2021, the U.S. Department of Labor (“DOL”) Employee Benefits Security Administration (“EBSA”) issued cybersecurity guidance directed towards ERISA plan sponsors and ERISA fiduciary advisors. While the guidance appears similar to SEC’s advice, there is one noticeable difference: the DOL says firms “should” have a reliable annual third-party audit of security controls. As part of this audit, EBSA expects to see audit reports, audit files, penetration test reports, and any other analyses or r...
To embed, copy and paste the code into your website or blog: As 2020 finally comes to a close, compliance officers face the unenviable job of performing their compliance program’s annual review under Advisers Act Rule 206(4)-7). An essential element of that review is updating the firm’s compliance policies and procedures to reflect relevant changes to regulations and regulatory guidance. Here’s a cheat sheet for Chief Compliance Officers summarizing the SEC’s big-ticket items from 2020. Despite the massive disruption caused by the COVID-19 pandemic, the SEC didn’t skip a beat, movin...