CSS Blog

News, updates and analysis from around the world of compliance

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

From Wall Street to Main Street: Update on Standard of Conduct for Investment Advisers

Retail investors are confused! They fundamentally cannot differentiate between a broker-dealer and an investment adviser. And that has the SEC concerned. So when the DOL Fiduciary Rule was overturned earlier this year, the SEC stepped into the debate with its April proposal. And that was a key topic of discussion at the recent CSS/Ascendant fall … Continued

Placing Ethics and Compliance in the Foreground of Business Decision-Making

Thinking about how to make ethics and compliance part of a business’s decision-making can prove to be challenging. By nature, compliance professionals are often results-oriented, focusing on a binary end-result; either you are in compliance, or you are not. That focus is important, but emphasizing process is also vital, John Walsh, Partner at Eversheds Sutherland … Continued

What Am I Looking At? Making Sense of Your Cyber Testing Reports

It’s no surprise that Compliance and IT do not speak the same language. Compliance staff often speak in terms of regulations and policies, whereas bits and bytes are the language of IT staff. This distinction is clear when it comes to cybersecurity risk management, as the compliance and IT audiences are looking for different takeaways … 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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