CSS Blog

News, updates and analysis from around the world of compliance

Countdown to CCPA: Are You Ready to Comply with New Data Privacy Requirements?

With less than one month before the California Consumer Privacy Act (CCPA) is effective, companies are preparing to update their cybersecurity programs. Many must address the regulation’s new data privacy requirements, which have caught some financial institutions off guard. Modeled to some extent after the European Union’s General Data Protection Regulation (GDPR), the CCPA provides … Continued

ESMA Updates AIFMD Q&A on Reporting to National Competent Authorities

The European Securities and Markets Authority (ESMA) has updated its Questions and Answers on the Alternative Investment Fund Managers Directive (AIFMD). One new Q&A has been added with regard to reporting to National Competent Authorities. ESMA has provided clarification on reporting on liquidity stress tests for closed-ended unleveraged Alternative Investment Funds (AIFs). These AIFs are exempt from the … Continued

Proposed Amendments to Transaction Cost Calculations under PRIIPs

The European Supervisory Authorities (ESAs) recently issued a consultation paper that includes two draft proposals for changes to transaction cost calculation requirements outlined in Annex VI points 7-23, among other proposed amendments to the PRIIPs KID. The first proposal seeks to reduce the impact of negative implicit costs on net transaction cost disclosures, in addition … Continued

Introducing the Regulatory Book of Record (RBOR)

I recently had the opportunity to sit down with our Chief Product Officer Ronan Brennan to discuss regulatory data management in front of an intimate and engaged audience of CSS conference attendees in Scottsdale, Arizona. The group ranged from small fund managers to large institutional asset managers, so it was difficult to boil down the … Continued

SEC Sets Clear Expectations Regarding Registered Investment Companies’ Compliance Programs

Chief Compliance Officers, Trustees and Service Providers to registered investment companies (RICs) be fair warned … the SEC’s Office of Compliance Inspections and Examinations (OCIE) has issued a Risk Alert identifying the most common deficiencies identified in examinations of RICs and providing observations with respect to money market funds and target date funds. With respect … Continued

SEC Proposes Amendments to Advertising Rules

In a proposal that would mark the first changes since 1961, the SEC has introduced amendments to modify the “Advertisements by Investment Advisers” Rule 206(4)-1 of the Investment Advisers Act. Changes to the rule would allow for testimonials and social media practices beyond that currently allowed, and performance marketing subject to new requirements. Some parts … Continued

Technology Advances Here and On the Way for Form CRS

CSS featured a strong presence at the recent 2019 BAM + Loring Ward Advisor National Conference in St. Louis, Mo. The conference, titled “In Our Element,” explored the chemistry of investment advisors’ relationships with their clients and the keys to successfully building those relationships. Within that context, CSS’s compliance presentation outlining the purpose and implementation … Continued

Tips From the Field to Enhance Your Compliance and Supervisory Programs

At the recent CSS Fall 2019 Conference, experienced professionals Jeff Blumberg of Faegre Baker Daniels and John Gentile of CSS provided practical solutions for in-house compliance pros. Regulators, in-house compliance personnel, and outside compliance and legal counsel understand all too well that compliance should not be a separate department from the rest of the advisory … Continued

As SFTR Deadline Looms, Time to Take Control of Your Data

Looming regulatory deadlines – such as the impending roll-out of Europe’s Securities Financing Transactions Regulation (SFTR) – are rarely welcomed by compliance teams at buy- and sell-side firms. But the introduction of this complex and far-reaching regulation, starting April 2020, offers market participants a significant opportunity. Firms that have so far adopted a tactical approach … Continued

Data Quality the Key to Meeting Challenge and Opportunity of Cost Transparency

Technology has done much to increase cost transparency in recent years, yielding considerable power – and savings – to consumers. Price comparison websites, for example, make it easy for us to weigh the costs of regular household expenditure items – from holidays to utility services to home insurance – across multiple providers. Behind the technology … Continued

Tips to Prevent an SEC OCIE Investment Adviser Exam from Going Bad

Strategies to employ when an SEC OCIE adviser exam goes bad drew a great crowd at the recent CSS Ascendant Fall Compliance Conference. Proactively pointing an exam in the right direction was a consistent theme, summarized by the familiar refrain: “There is no substitute for preparation.” A few keys to note if you find your … 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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