CSS Blog

News, updates and analysis from around the world of compliance

Are Investment Managers Going to Have More KIDs?

Let us be clear…. we’re actually talking about the potential increase in production of point-of-investment disclosure documents for investment managers. The complications and stress of Brexit just got a whole lot more real for many UK- and EU-based investment management companies that are subject to rules requiring production of UCITS KIID (Key-Investor-Information-Document) and PRIIPs KID … Continued

SEC’s New Committee Begins Review of Form CRS Filings

The SEC’s Divisional Standards of Conduct Implementation Committee launched its review of Form CRS from a cross section of RIAs and BDs to assess compliance with the content and format requirements. Initial observations from the Committee have identified examples of relationship summaries that may lack certain disclosures or could be clearer or otherwise improved. The … Continued

Proposed Amendment to 13F – What This Really Means?

The SEC released a proposed amendment to Form 13F on July 10 to update the reporting threshold for institutional investment managers and make other targeted changes. The threshold has not been adjusted since the Commission adopted Form 13F over 40 years ago. New Proposed Reporting Threshold: The proposal would raise the reporting threshold to $3.5 … Continued

SEC Issues New Cyber Risk Alert to Financial Firms

Financial firms have a bigger target on their backs at the moment, according to a new risk alert issued July 10, 2020 by the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE).  This new risk alert on ransomware cautions investment advisers, broker-dealers, and investment companies that OCIE has recently observed a marked … Continued

LIBOR No More: SEC Focuses on LIBOR Transition Preparedness

With the discontinuation of LIBOR expected in 2021, the SEC has identified that it will have a significant impact on the financial markets and may present a material risk for SEC-registered investment advisers and broker-dealers.

Keep Your Eye on the Prize

For ERISA plan fiduciaries who thought they were being responsible and addressing participants’ demands by including investments in employee retirement plans that also support non-financial objectives, such as environment, social and corporate governance (“ESG”) goals, the Department of Labor (“DOL”) has weighed in. And they don’t necessarily agree. In a proposal announced June 23, 2020, the … Continued

FINRA Enhanced Security Features for Super Account Administrators (SAAs) and Account Administrators (AAs)

FINRA recently deployed a new security feature for users of the Web CRD and IARD systems which is being rolled out to firms in phases over the next several months. FINRA is implementing Multi-Factor Authentication (MFA) which will add an additional layer of security for Super Account Administrators (SAAs) and Account Administrators (AAs) verifying their … Continued

Regulatory Changes to Sensitive Industries

The outbreak of the COVID-19 pandemic and the resulting market volatility have led several governments to amend law and regulation in the context of sensitive industries (SI). SI refers to two distinct types of investment restrictions: 1) foreign direct investment (FDI) restrictions, often part of national security screenings of incoming foreign capital and 2) sector-specific … Continued

Global Short Selling Restrictions in a COVID-19 Economy

Since the outbreak of the COVID-19 pandemic and the resulting lockdown of Wuhan, China on 23 January 2020, world markets have seen unprecedented swings, developed and developing countries alike have experienced severe economic damage, and regulators around the world have taken swift and significant actions in attempts to stave off further financial turmoil. For investment … Continued

Shareholder Disclosure: Low Notification Thresholds in Europe

Among the hundreds of threshold reporting rules throughout Europe that affect investment managers, a significant number apply to long or short positions of 1% or lower. And because the applicable rules are the local laws of wherever the issuer is based or listed, a market participant with exposure in various European issuers could be subject … Continued

Don’t Forget the Disclosure Obligation

Recently, the SEC announced the settlement of an enforcement case against Morgan Stanley Smith Barney (MSSB) involving charges that MSSB provided misleading information to its clients in connection with trading costs in its retail wrap fee programs. MSSB agreed to pay a $5 million penalty that will be distributed to harmed investors. The case is … 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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