Posts By: Jackie Hallihan

Breakdown of OCIE’s COVID-19 Compliance Risks Alert

The SEC’s “Office of Compliance Inspections and Examinations (“OCIE”) issued an Alert today regarding “Select COVID-19 Compliance Risks for Investment Advisers and Broker-Dealers.” OCIE shared observations regarding six broad categories: protection of investors’ assets; supervision of personnel; practices relating to fees, expenses, and financial transactions; investment fraud; business continuity; and the protection of investor and … Continued

SEC’s New Committee Begins Review of Form CRS Filings

The SEC’s Divisional Standards of Conduct Implementation Committee launched its review of Form CRS from a cross section of RIAs and BDs to assess compliance with the content and format requirements. Initial observations from the Committee have identified examples of relationship summaries that may lack certain disclosures or could be clearer or otherwise improved. The … Continued

As Form CRS Compliance Date Nears, Approaches to Meet Challenge Coming Into Focus

Form CRS, the sleeping giant, awakens! Investment advisers and broker dealers are turning their attention to planning for Form CRS, training and developing procedures to implement the SEC’s new rule and related interpretive releases. CSS developed Form CRS Automator, a software tool, to streamline the process. It allows teams to quickly produce compliant and accurate … Continued

10 Compliance Tips for Starting 2020 Off on the Right Foot

No rest for the weary. With the new year upon us, our attention turns to new budgets, change and planning. With renewed energy as we roll into January thaw, we worry if our compliance program is ready. To give you a leg up, here are 10 tips for investment adviser and broker-dealer compliance teams for … Continued

Tips to Prevent an SEC OCIE Investment Adviser Exam from Going Bad

Strategies to employ when an SEC OCIE adviser exam goes bad drew a great crowd at the recent CSS Ascendant Fall Compliance Conference. Proactively pointing an exam in the right direction was a consistent theme, summarized by the familiar refrain: “There is no substitute for preparation.” A few keys to note if you find your … Continued


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