CSS Blog

News, updates and analysis from around the world of compliance

How Do You Supervise for SEC Pay-to-Play Violations?

If you wanted more information about the contours of the SEC’s Pay-to-Play Rule, or how the SEC may enforce it, three recent Settlement Orders against large investment advisers for “over de minimis” political contributions provide some insight regarding one of the prohibitions: Contributions by Covered Associates to certain Government Officials over the specified Exception amount (capitalized words are terms in the … Continued

Upcoming ComplianceCast™: The Compliance Professionals Guide to Effective Trade Desk Monitoring

Global regulators continue to enhance their ability to monitor the activities of market participants through a combination of new rules, filing requirements, and upgrades to surveillance technologies. As a result, many market participants, including both buy- and sell-side firms, need to re-assess how they currently monitor the trading desk, and whether new policies and procedures are needed to effectively manage reputational risk and avoid costly fines.

Hamilton Lane Announces Successful Form ADV Filing Through Consensus

Leading alternative investment management firm Hamilton Lane recently announced that it successfully filed its Form ADV using Compliance Solutions Strategies’ Consensus platform. “Consensus simplified our Form ADV reporting process,” Hamilton Lane Chief Compliance Officer Fred Shaw said in a press release marking the announcement. “We leveraged the platform’s automated data upload functionality to report efficiently … Continued

Do Your Fund Documents Clearly Disclose Receipt of Accelerated Monitoring Fees?

Somewhat more reminiscent of the broken-windows enforcement era, two affiliated private equity advisers managing billions settled with the SEC on charges that they failed to make pre-commitment disclosures in fund governing documents related to accelerated fees received from portfolio companies. Interestingly, according to the Settlement Order, the advisers had made some disclosures in fund documents … Continued

With New Risk Alert, SEC Doubles Down on Best Execution

On July 11, 2018, the SEC issued a Risk Alert outlining commonly found compliance issues related to best execution by investment advisers. Advisers have an obligation to seek best execution of client transactions, taking into consideration quantitative factors such as execution quality and commission rate, as well as more qualitative factors such as the value … Continued

California Privacy Law Brings ‘GDPR-Lite’ to the U.S.

In what has become an ongoing race among states to have the toughest privacy regulation in the U.S., California has jumped to the front. On June 28, 2018, California’s legislature unanimously passed a privacy bill that was later signed by Governor Jerry Brown, which simultaneously strengthens privacy protections for California residents while possibly mooting an … Continued

CSS CRO Jeanette Turner on Bloomberg Markets

CSS’ global profile continues to rise. Chief Regulatory Officer Jeanette Turner recently appeared on Bloomberg Markets: Rules & Returns to discuss changing approaches to compliance, data management and reporting requirements, with an emphasis on two CSS strengths: technology and automation. “For reporting, which is the new thing that regulators are focused on – they love … Continued

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