CSS Blog

News, updates and analysis from around the world of compliance

Regulation Best Interest, Cybersecurity Top Concerns at IAA 2019 Compliance Conference

The Investment Adviser Association (IAA) represents the interests of investment advisers in Washington D.C., and the IAA Investment Adviser Compliance Conference 2019 was a forum for the discussion of future potential rulemaking. Cybersecurity and Fiduciary Rule considerations were headline topics, with custody and marketing right behind. The following is a summary of key issues discussed … Continued

Shareholder Monitoring and Disclosures: Keeping One Step Ahead of the Front Office

Fresh from our London conference “Looking at the Year Ahead – Global Compliance and Data Priorities” – a rousing success! – we’ll cover takeaways from a key panel discussion on shareholder monitoring and disclosures. Two of the best in the business were in the house (or should we say “in the brewery,” an amazing London … Continued

The Challenges of Building a Global Compliance Program

Compliance programs face challenges in balancing global requirements with local exceptions while incorporating the fast pace of regulatory change, addressing critical business needs and obtaining the necessary resources necessary to manage the program. Trends and thinking on the subject were center stage at the recent CSS London event “Looking at the Year Ahead – Global … Continued

Coming to America – California Adopts GDPR-Like Privacy Regulation

After a number of firms struggled last year to get their marketing and information systems into compliance with the EU’s General Data Protection Regulation (GDPR), advisers to U.S. clients will soon be facing similar requirements on the home front. On the heels of the Cambridge Analytica scandal, California enacted the California Consumer Privacy Act of … Continued

An Overview of MMFR – Article 37 Reporting Requirements

The European Union’s Money Market Funds Regulation (MMFR) applies to any Money Market Fund (MMF) that is authorized as a collective investment scheme under either the Undertakings for the Collective Investment in Transferable Securities Directive (UCITS) or the Alternative Investment Fund Managers Directive (AIFMD). Managers subject to UCITS or AIFMD will continue to be regulated … Continued

SEC Reopened After 35-Day Government Shutdown

SEC Chairman Jay Clayton announced on Saturday, January 26 that with an agreement reached to end the government shutdown, the “Commission has resumed normal staffing levels and is returning to normal operations.” In total, about 94% of the commission’s approximately 4,400 employees had been furloughed during the 35-day shutdown, according to its operations plan. In a … Continued

FINRA Rolls Out New Central Registration Depository Functionality; Annual Verification Deadline Nears

FINRA first introduced enhancements to the Central Registration Depository (“CRD”) on October 1, 2018, which were rolled out in support of FINRA’s restructured qualification examination program as well as the adoption of consolidated FINRA registration rules. The new enhancements were intended to also more easily assist member firms with satisfying their reporting and compliance obligations. … Continued

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


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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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