ComplianceCasts™

Performance Advertising and Fees disclosures: Best practices for SEC and GIPS compliance

The advertisement of investment performance is a critical risk area for private investment fund managers in terms of regulatory compliance and for capital raising. Several recent SEC enforcement cases have highlighted the importance of adequately disclosing fee practices and other conflicts of interest to fund investors in advertisements and investor reports, and of adequately reporting … Continued

Getting Smart about Cybersecurity

Most firms have addressed cybersecurity in one aspect or another, thinking a few access controls and anti-virus programs are the silver bullet. However very few firms have a holistic cyber program in place, often lacking in high-risk areas while having an excess of controls in others, wasting time and resources that should be spent elsewhere. … Continued

Insurance Considerations for Investment Advisers

How much coverage is enough? What types of insurance policies do you need? Whether you are starting an investment advisory practice, launching a new line of business, or reevaluating your existing risks, there are critical questions to ask to make sure you understand the various ways to protect your firm. Join us for a practical … Continued

Custody – Get It Right: Just in Time for Your Annual Updating Amendment!

The SEC’s Custody Rule and its application to registered investment advisers is complicated and often misunderstood, and custody issues remain among the most common deficiencies cited during SEC exams. Download this important ComplianceCast to understand the key elements of the Custody Rule; identify available exceptions to certain requirements of the Custody Rule based on industry … Continued

SEC and FINRA 2018 Examination Priorities

The SEC and FINRA have recently released their examination priorities for 2018. These releases provide insight into regulatory priorities and serve as guidance for a firm in evaluating its compliance program. We will discuss topics covered in these releases, including: Protecting retail investors Disclosure Best execution Mutual fund selection Anti-money laundering Cryptocurrencies Technology and cybersecurity … Continued

Due Diligence of Sub-Advisers and Other Third-Parties

November’s Compliance Cast will look at the Adviser/Sub-adviser relationship, from the standpoint of sub-adviser. During the session, we will discuss: Qualities of an attractive sub-adviser candidate Initial and ongoing due diligence expectations Communications with the primary adviser Compliance and operational issues The session will be presented by Melanie Mendoza and Matt Calabro of Ascendant, and … Continued

Ethics: Building a More Ethical Workforce

How to make ethics part of your Firm’s Compliance Culture Where does the requirement to act ethically come from? Dealing with Ethical Dilemmas 2016 SEC Enforcement Cases that pertain to Ethics Fill in the form below to download this ComplianceCast™

One Phish, Two Phish, Red Phish, Blue Phish: How to Detect and Mitigate Social Engineering and Ransomware Techniques

Ransomware attacks like WannaCry and NotPetya are increasing in both frequency and damage, routinely making headline news with their abilities to bring down networks of established companies. Yet these cyberattacks typically start by compromising the weakest point in your security chain – people – through simple or complex phishing techniques before spreading to other parts … Continued

Form ADV: What You Need to Know Now to Prepare for October

October 2017 new Form ADV amendments continue the big data trend. Form ADV continues to expand ever more rapidly as data mining and handling techniques by regulators allow for the utilization of Form ADV for risk measurement. Ease the burden of answering over 100 separate questions (plus scores more for each private fund) through this … Continued

Advertising & Marketing Compliance: The Rules, Hot Topics & Reviewing Tips

This ComplianceCast covers the following topics: Investment Adviser Advertising Rules and No-Action Guidance Performance Advertising – General Requirements, Model Performance & Hypothetical Back-tested Performance Use of Third-Party Performance in Advertising – Disclosures & Caveats Considerations for Different Types of Media Anatomy of Reviewing Advertising Materials – Illustration of the Review Process & Key Considerations Fill … Continued

Join the Discussion: Live Advice on Managing Your Firm’s Due Diligence Process

Your firm can outsource an activity to third-party vendors, but it still retains oversight responsibility. This ComplianceCast is designed to review industry practices pertaining to identifying and monitoring service providers and address your questions about developing and implementing a due diligence program through an active Q&A roundtable discussion. Our panel of veteran due diligence professionals … Continued

Planning for the Worst: Business Continuity Planning and Transition Planning

The presidential election as well as the current composition of the SEC has potential impacts for many regulations, including one of the biggest new rule proposals from the SEC: Rule 206(4)-4. With implications for both compliance and operations, the rule is intended to ensure that your firm’s services to its clients continue when you’re faced … 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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