CSS Blog

News, updates and analysis from around the world of compliance

Report on Operation of AIFMD Highlights Existing Issues

On 10 January 2019, the European Commission (EC) published a report on the operation of the Alternative Investment Fund Managers Directive (AIFMD). The report confirms that AIFMD has significantly contributed to creating a single market for alternative investment funds by establishing a harmonized regulatory and supervisory framework. However, it also identifies various topics that will … Continued

SEC’s Latest Risk Alert Focuses on Electronic Communications

The SEC’s most recent risk alert, “Observations from Investment Adviser Examinations Relating to Electronic Messaging,” issued on December 14, 2019, focuses on the use and maintenance of electronic communications for business purposes. The purpose of the alert is to remind advisers of their obligations related to personal use of electronic messaging and the requirements for … 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

CSS Shortlisted for Two HFM US Hedge Fund Technology Awards

We are proud to announce that Compliance Solutions Strategies has been shortlisted in two categories for the HFM US Hedge Fund Technology Awards 2019. We are one of nine finalists for the Best RegTech solution award for our best-in-class solutions, which cover regulatory reporting, regulatory data management, compliance services, and trade monitoring & analysis. We are … Continued

European Commission Approves Draft Technical Standard for SFTR

After several delays earlier this year, the European Commission has finally approved the draft technical standard (RTS) for SFTR. The European Parliament now have up to six months to scrutinize the legislation, which has been changed from the previous three-month suggestion. That means that the regulation will be published in the official journal by July … Continued

SEC Retail Investor Focus Turns Towards Registered Investment Companies

Earlier this year when the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2018 examination priorities, OCIE stated that a core priority was to protect retail investors, including seniors and individuals saving for retirement. OCIE is now continuing this effort by focusing on mutual funds and exchanged-traded funds (together, the “Funds”) as the … Continued

SEC Alerts Investment Advisers to Review Solicitor Arrangements

On October 31, OCIE issued a new Risk Alert for investment advisers with solicitor arrangements. The SEC periodically releases risk alerts to notify the industry of deficiencies they are finding during examinations, and this latest alert puts investment advisers with solicitor arrangements on notice to check their solicitor agreements, policies and procedures, and disclosure documents. … Continued

Pennsylvania Sounds Warning Bell Over Client Credentials and Custody

The Pennsylvania Department of Banking and Securities (PDOBS) has indicated in recent guidance two concerns related to investment advisers using client credentials to access a custodial account(s). In the letter dated September 25, 2018, PDOBS indicates that the use of client credentials may create custody and is considered to be a dishonest and unethical practice. … Continued

Advertising Issues: SEC and GIPS Performance in the Private Fund Space

Over a year ago, OCIE released the Risk Alert, “The Most Frequent Advertising Rule Compliance Issues Identified in OCIE Examinations of Investment Advisers.” While the alert highlighted several areas where performance advertising is involved, our recent CSS/Ascendant conference panelists in a session entitled “Best Practices for SEC and GIPS Performance in the Private Fund Space” … 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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