Posts By: Michael Chiappetta

SEC Proposes Modernizing Advertising and Cash Solicitation Rules for Investment Advisers

In a much-anticipated move, the Securities and Exchange Commission (the “Commission” or the “SEC”) recently voted to propose amendments to modernize rules that prohibit certain investment adviser advertisements and payments to solicitors under Investment Advisers Act of 1940 (the “Advisers Act” or the “Act”). The proposal also contemplates amendments to Form ADV to require additional … Continued

Form CRS & Conversation Starters Made Easy: Practical Application & Tips for Investment Advisers, Dual Registrants & Broker-Dealers

In this ComplianceCast webinar, co-executive directors of CSS compliance services Jackie Hallihan and Keith Marks address the challenges of Form CRS as firms prepare for its June 2020 compliance date. Topics include: Practical considerations for Form CRS How to manage Conversation Starters Conversation starter challenges: supervision, training, more… Where to start? Roadblocks? Identifying conflicts and … Continued

How Organizations Can Promote Ethics

Written ethical standards are useless if employees – especially a firm’s leadership – don’t follow them. CSS Ascendant Consultant Victoria Olson and seasoned Ethics Officer, Kimberly Tabb, JD, teach how you can breathe new life into your written Code of Ethics. This ComplianceCast explores ways that organizations of all sizes can promote ethical behavior and … Continued

“Getting Practical with Cyber” Series, Part III: Updating Your Cyber Policies to Align with Recent SEC Exams

Cyber regulations are changing with the speed of light, with the SEC, FINRA, CFTC, and NFA all issuing risk alerts and other guidance in the last two years. This comes on the heels of state regulations getting more and more stringent with respect to data protections. With regulators now issuing detailed cybersecurity deficiencies during regulatory … Continued

Signal – Shareholding Disclosure Case Study

Case Study Signal is CSS’s solution for shareholder disclosure notification requirements globally. It tracks threshold violations and generates disclosures based on market-enriched customer holding, security, portfolio and trade data. Signal’s substantial shareholding solution covers long, short and takeover panel reporting across 90 jurisdictions globally. Signal’s client base includes traditional and alternative asset managers, as well … Continued

Effective Compliance Policies & Procedures and Annual Reviews: Meeting the Reasonably Designed Standards

Investment Advisers must perform an annual evaluation of the effectiveness of their compliance program. This starts with ensuring, maintaining and implementing reasonably designed policies and procedures. This ComplianceCast webinar covers the recent regulatory changes that may trigger a need to reevaluate your present policies. Who Conducts and How to Conduct the Annual Review Planning and … Continued

7 Reasons to Attend Our Scottsdale Fall 2019 Compliance Conference

If you’ve been considering joining us in Scottsdale for our Sept. 23-25 compliance event, here are seven reasons you should take the plunge now! The Best Mix of Informational & Educational Speakers – We just added OCIE’s Co-National Associate Director of Investment Adviser/Investment Company Examination Program Marshall Gandy to our stellar list of presenters. He joins ex-NFL star Merril … 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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