CSS Blog

News, updates and analysis from around the world of compliance

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

Tips for Developing a Tailored Private Fund Compliance Calendar

As regulatory concerns proliferate and become more complex, developing and monitoring your “to-do” list becomes of paramount importance.  John Gentile, the Director of Private Fund Manager Services for Compliance Solutions Strategies and Michael Emanuel, a Partner at Stroock & Stroock & Lavan LLP provided attendees of the recent CSS 2019 Fall Conference some insight into … Continued

Brexit: Implications for Shareholders with Threshold Interests

As yet another deadline approaches for the United Kingdom to either leave the European Union with a withdrawal agreement in place or else exit effective immediately in a “no-deal” scenario, it is worth examining how this would affect asset managers subject to the UK regimes for major shareholdings, short selling, and dealing disclosures. First, the … Continued

Recent Privacy Law Changes for Advisers a Focus of Cyber Discussion in Scottsdale

Regulators and legislators certainly have been busy in 2019, leaving little breathing room for financial firms. More data privacy laws are on the horizon, particularly at the state level, with some very real implications for SEC-registered investment advisers. That was the key message from the “Regulatory Update on Privacy Regulations and Cybersecurity” panel during the … Continued

Virginia Investment Adviser Rules Amended – September 16, 2019 Compliance Date

Last week we discussed the changes to the Massachusetts IA Disclosure Rule. That is not the only state legislature that has been busy. On August 21, 2019, the Virginia State Corporation Commission adopted revisions to Chapters 20, 30, 45, and 80 of Title 21 of the Virginia Administrative Code. The amendments impact Virginia state registered … Continued

Updates to the Massachusetts Investment Adviser Disclosure Rule

The states continue to be busy with new rule-making! On June 14, 2019 the Massachusetts Securities Division (the ‘Division’) adopted amendments to 950 Massachusetts Code of Regulations 12.205(8). The amendments, applicable to Massachusetts registered advisers, includes two elements, but the key one that we’ll focus on here is the requirement for Massachusetts registered investment advisers … Continued

Improving Mutual Funds’ Principal Risks Disclosure

The Securities and Exchange Commission (SEC) has for years stressed that registrants’ disclosure in regulatory filings needs to be written in “plain English.” The SEC’s Disclosure Review and Accounting Office recently reiterated the plain English directive in “ADI 2019 – 08 – Improving Principal Risks Disclosure.” The guidance focuses specifically on making disclosure of principal risks … Continued

CFTC Orders Firm to Pay $1.5 Million in Connection with Phishing Cyber Breach, Cites Inadequate Cyber Training

The Commodity Futures Trading Commission (CFTC) isn’t holding back when it comes to holding firms accountable for protecting their client’s funds and information. On September 12, 2019, the CFTC issued an order bringing proceedings against a registrant to the tune of $1.5 million US relating to claims that the registrant violated Commission Regulations 166.3 and … Continued

Cayman Islands Data Protection Law Nears Taking Effect

Cybersecurity regulations have landed ashore on the islands, and life is about to become anything but a beach for firms forced to comply with the Cayman Islands’ new Data Protection Law (DPL), slated to take effect September 30, 2019. With provisions largely mirroring the EU’s General Data Protection Regulation (GDPR), entities with a presence or … 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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