Posts By: Allison Fraser

The Case for an Interim Evaluation of your Compliance Program

How prepared was your firm for the disruption of COVID-19 pandemic? Did your firm’s business continuity plan cover a pandemic? Have you adapted your compliance program since March? The COVID-19 pandemic has forced many to rethink best practices in the face of adapting to the “new normal.” Whether your firm is continuing to work from … Continued

SEC Grants Section 17a No-Action Relief to Open-End Funds

The SEC has taken many actions in the past month to provide relief to registrants and the financial services industry during the COVID-19 national emergency. Another recent action is the relief granted by the SEC to open-end investment companies that are not exchange-traded funds and are not considered money market funds (“Funds”). The relief, granted … Continued

SEC Sets Clear Expectations Regarding Registered Investment Companies’ Compliance Programs

Chief Compliance Officers, Trustees and Service Providers to registered investment companies (RICs) be fair warned … the SEC’s Office of Compliance Inspections and Examinations (OCIE) has issued a Risk Alert identifying the most common deficiencies identified in examinations of RICs and providing observations with respect to money market funds and target date funds. With respect … Continued

Improving Mutual Funds’ Principal Risks Disclosure

The Securities and Exchange Commission (SEC) has for years stressed that registrants’ disclosure in regulatory filings needs to be written in “plain English.” The SEC’s Disclosure Review and Accounting Office recently reiterated the plain English directive in “ADI 2019 – 08 – Improving Principal Risks Disclosure.” The guidance focuses specifically on making disclosure of principal risks … Continued

SEC Reopened After 35-Day Government Shutdown

SEC Chairman Jay Clayton announced on Saturday, January 26 that with an agreement reached to end the government shutdown, the “Commission has resumed normal staffing levels and is returning to normal operations.” In total, about 94% of the commission’s approximately 4,400 employees had been furloughed during the 35-day shutdown, according to its operations plan. In a … 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


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