Posts By: John Gentile

SEC Continues Scrutiny of Private Fund Cross Trades

The SEC continues to scrutinize principal and cross-trade transactions in the private fund world. Are such trades illegal? No. In fact, with sufficient disclosures (and supervisory controls, of course), a private fund adviser can conduct principal and cross trades, which can offer certain benefits to the funds under management. For example, cross trades can be … Continued

Pathway to Reg BI Compliance: Have You Started Your Conflict of Interest Assessment?

As the June 30, 2020 compliance date for the SEC’s Regulation Best Interest (“Reg BI”) draws near, broker-dealers are scrambling to design and implement a comprehensive solution to ensure compliance with Reg BI. In short, Reg BI requires that broker-dealer recommendations be in the retail client’s best interest, creates a broad disclosure obligation, and compels … Continued

Takeaways from FINRA’s Examination Priorities 2020

The much-anticipated release of the Financial Industry Regulatory Authority, Inc. (“FINRA”) 2020 Risk Monitoring and Examination Priorities Letter occurred on January 9, 2020. Why is this annual release so important to broker-dealers? In short, it serves as a roadmap to identify compliance and supervisory topics that will underpin FINRA’s examination program as 2020 unfolds. After … Continued

FINRA Announces Revamped Examination and Risk Monitoring Program

FINRA has consolidated its three examination programs into a single program, a process that started in October 2018. As part of this consolidation, on December 12, 2019 FINRA announced the senior leadership team under the new examination and risk monitoring structure within the organization. The goal of the reorganization is to drive more effective risk … Continued

Reorganization of FINRA’s Examination Program Taking Shape

At FINRA’s recent annual conference in Washington D.C., President and CEO Robert W. Cook and Executive Vice President of Member Supervision Bari Havlik discussed, among other things, FINRA’s ongoing efforts to consolidate its Examination and Risk Monitoring Programs from three separate programs into a single one. The goal of the reorganization is to drive more … Continued

Even When SEC Rulemaking Slows, Your Compliance Manual Shouldn’t Stagnate

Maintaining tailored policies and procedures is a critical component of an adviser’s internal controls. Time and time again, we’ve heard regulators admonish the industry that off-the-shelf compliance manuals just don’t cut it. In today’s ever-shifting regulatory environment, does your compliance manual need a reboot? Although there has not been any significant rule making over the … Continued


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