CCOs Acting Like Ostriches Will Earn You an SEC Bar
A chief compliance officer (“CCO”) for a registered investment adviser (“RIA”) found himself barred from any compliance or supervisory role in the future because he willfully refused to fix a number of...
View ArticleClik here to view.
Coronavirus Reaches Pandemic Status: You Better Pull Out the Old Business...
Let’s be honest, the only people usually concerned about business continuity plans (“BCP”) are compliance folks and the lawyers. In fact, many probably have not looked at their BCP since Hurricane...
View ArticleClik here to view.
Reg BI and Form CRS Are More Important to the SEC Than the Pandemic
Unfortunately, in a very short sighted move by the United States Securities and Exchange Commission, its Chairman Jay Clayton announced that the SEC would not extend the compliance date for Regulation...
View ArticleClik here to view.
Securities Regulators Will Be Conducting Exams on BCPs
Last month, we discussed business continuity plans and how important they were to firms. Further, my partner, Josh Horn, and I, recently, conducted a webinar for the NSCP on this very topic. Now, we...
View ArticleSEC and States Provide Relief for Upcoming Proxy Season Due to COVID-19
As proxy season approaches for a number of public companies, the Securities and Exchange Commission (SEC) and certain state authorities have taken steps to revise their current corporation laws or...
View ArticleFox Rothschild’s Securities Industry Group Members Oksana Wright and Charles...
Oksana Wright and Charles DeMonaco discuss the management and corporate compliance measures for the companies to prioritize during the time of cost-cutting and uncertainty:...
View ArticleClik here to view.
Risk Factor Considerations in the time of COVID-19
By Jesse Fishman and Laura Holm In Quarterly Reports on Form 10-Q, companies are required to disclose any material changes to risk factors that were included in their most recent Annual Report on Form...
View ArticleClik here to view.
SEC Readying to Hammer BDs and RIAs Over COVID19 Compliance Risks
The SEC’s Office of Compliance and Inspections (“OCIE”), recently, issued an alert—more like a shot across the bow—to BDs and RIAs regarding its concerns over activities in the industry concerning the...
View ArticleClik here to view.
SEC Prepping for a New Round of Attacks on Fund Advisers
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) conducted a series of examinations into private fund advisers. See the SEC risk alert here. To say the least, OCIE was not pleased...
View ArticleClik here to view.
New SEC Division Undertakes 2021 Examination Priorities
On December 17, 2020, SEC created the Division of Examinations by renaming the now defunct, Office of Compliance Inspections and Examinations, making it the SEC’s 6th Division joining Enforcement,...
View Article
