Posts By: Matt Calabro

The Lasting Impact of COVID-19 on Investment Management

The COVID-19 pandemic and related shutdown of global economies will be remembered as one of the most significant shocks to the investment management industry. In early 2020, global economies were generally strong. By mid-March, the U.S. was in a full-blown credit crisis, with credit markets seizing, buyers were avoiding even “safe” investments like U.S. Treasuries … Continued

Don’t Forget the Disclosure Obligation

Recently, the SEC announced the settlement of an enforcement case against Morgan Stanley Smith Barney (MSSB) involving charges that MSSB provided misleading information to its clients in connection with trading costs in its retail wrap fee programs. MSSB agreed to pay a $5 million penalty that will be distributed to harmed investors. The case is … Continued

Eventually, We Have to Go Back – BCP Post-Mortem

We don’t know when, but at some point we will have to put on shoes, get a haircut and return to the office. As compliance professionals, we are trained to look ahead and should be planning our action steps for when we return. Gather Firm Records and Other Property. You should have a good sense … Continued

Compliance Lessons Learned in 2019

Now that we are in mid-January, a few things are evident. We have likely broken one or more New Year’s resolutions, the effect of any rest over the holidays has worn off and we need to complete our annual compliance reviews for 2019 and firm up our 2020 plans. While I don’t have solid advice … Continued

SEC Issues Guidance to Investment Advisers on Proxy Voting

At its August 21, 2019 Open Meeting, the Securities and Exchange Commission (“SEC”) voted 3-2 to issue guidance to assist registered investment advisers (“RIAs”) in carrying out their proxy voting responsibilities. While the guidance didn’t break a lot of new ground, it clarified the SEC’s expectations for investment advisers in voting client proxies and engaging … Continued

Life Cycle Guidance for Service Provider Due Diligence

Engaging third-party service providers to perform key functions can offer an investment adviser access to state-of-the-art technology and solutions necessary to compete in today’s environment. Before entering into service provider relationships, advisers need to understand that while the function may be outsourced, the responsibility for the function still rests with the adviser. Firms engaging service … Continued

Mitigating the Risk of Insider Trading

One of the biggest risks affecting investment advisers is the potential that material non-public information (“MNPI”) may be misused, leading to a charge of insider trading. Advisers should implement controls to mitigate these risks. Steven Stone of Morgan, Lewis & Bockius, LLP, Salvatore Cincinelli of the FBI and David Chaves of Tone at the Top … Continued

It Takes a Village – Preparing for a Regulatory Exam

Advanced planning for a regulatory exam remains a vital step in ensuring the compliance team is prepared when the exam teams comes knocking. At the recent CSS/Ascendant fall conference in San Diego, Allison Fraser moderated the conference’s capstone session on the topic, joined by Bryan Bennett, the Associate Regional Director in the examination program in … Continued


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