Posts By: Korrine Kohm

Time to Use the Bat Phone: Who to Call When a Compliance Officer Needs Help?

It seems that the burden of work continues to increase for compliance professionals in the investment management industry. While also ensuring that their compliance program is effective, compliance officers must also be aware of cybersecurity threats, business continuity plans, new regulations, changes in business strategy, and more – all while doing this under a work … Continued

Business Continuity and Preparing for Regulatory Exams Post-Pandemic

As a compliance professional, the past months have probably been the most challenging of your career. Events, whether COVID-19, significant market fluctuations, halted stock exchange trading, or liquidity concerns, provided new and unique challenges for even a seasoned compliance professional. And while the focus on these new risks should take center stage for compliance officers, … Continued

Guidance for State-Registered Advisers Dealing with COVID-19

In addition to the SEC providing relief and support to investment advisers, the North American Securities Administrators’ Association (NASAA) and state regulators have also provided guidance in the form of a very helpful resource page. The page includes information on temporary regulatory relief, as well as updates on the operating status of NASAA members. The … Continued

Several States Coordinating Regulation Best Interest Pre-Implementation Exam Survey

While the SEC moved full force in adopting Regulation Best Interest and Form CRS, state regulators were fairly silent on what steps they would take pertaining to this topic. It seems the sleeping bear has awoken early this winter with the recent multi-state survey being sent to state-registered investment advisers. Many states are conducting a … Continued

Giving Voice to Values: A New Approach to Ethics

The “Giving Voice to Values” program grew out of Professor Mary Gentile’s frustration of what was going on in both the financial industry and in higher education. She was frustrated and angry about the poor way that ethics was being taught in universities and applied in real-world scenarios. What developed out of her frustration is … Continued

The Challenges of Compliance for State-Registered Advisers

Are you the designated chief compliance officer of a state-registered investment advisory firm? If so, you must be clocking many extra hours these days! It seems the state regulators are just as busy as the Securities and Exchange Commission. New Jersey, Massachusetts and Nevada have all introduced their own Fiduciary duty standard rules. The North … Continued

Takeaways and Tips Related to SEC Risk Alert on Regulation S-P

On April 16, 2019, the SEC released a Risk Alert providing a list of compliance issues related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment advisers and broker-dealers. As with other risk alerts, these were deficiencies noted by OCIE in regulatory examinations. Though the deficiencies were fairly common … Continued

SEC OCIE Issues 2019 Examination Priorities

Well ahead of the New Year, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2019 examination priorities. In keeping with OCIE’s four “pillars” of promoting compliance, preventing fraud, identifying and monitoring risk, and informing policy, the Dec. 20 release provides a preview of key areas where OCIE intends to focus its limited … Continued


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CSS frequently publishes blog posts which are written by our team from their observations in the field, at conferences and through experiences with compliance professionals. These posts are designed to further knowledge and share industry best practices. Topics run the gamut, including Form ADV, cybersecurity, MiFID II, position limit monitoring, technology challenges and more. Complete and submit the brief form below to receive notifications when we publish new content.


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