Whitepapers

SFTR: An Operational Game Changer for the Market

Securities Financing Transactions Regulation (SFTR) requirements are expected to be adopted by the European Commission (EC) by Q1 2019. Prior to finalisation, the EC and the European Securities and Markets Authority (ESMA) must resolve some differences over the SFTR level 2 Regulatory Technical Standards (RTS), but no further material changes are expected.

The Current State of Market Manipulation In Financial Markets

Just a couple decades ago, our market infrastructure was dominated by only a handful of securities exchanges. Fast forward to the present day, and there are now 18 national securities exchanges registered with the Securities and Exchange Commission (SEC) under Section 6(a) of the Securities Exchange Act of 1934 (“Exchange Act”), 44 Alternative Trading Systems (ATS) and over 200 brokerdealers that internalize their customers’ trades.

Social Engineering & Ransomware

If you were asked to describe a hacker, what image comes to mind? If you’re like most, you are probably picturing unintelligible text flying across a monitor as young men in black hoodies attempt to break into networks, engaging in a very technical dance and speaking in terms the average layperson would not understand.

Diminished Capacity: How an Investment Adviser Can Protect Their Elderly Clients

All too often, we hear how another elderly investor was taken advantage of by some type of fraudster. Even more frequently, we receive queries from registered investment advisers (“RIAs”) asking what they can do about an elderly client they feel is being financially abused by a caregiver or who is suffering from diminished capacity challenges.

Due Diligence for Advisers & Sub-Advisers

In an April 2003 speech by Lori Richards, the then-director of the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations mentioned one area where she believed some less-than-meticulous care has been given: the supervision of service providers and in particular, sub-advisers.

Getting Smart About Cyber

When it comes to managing cybersecurity risk, investment advisers are in a tough position. As the frequency and variety of cybersecurity risks mount, IT budgets and staffing do not always follow suit. Compliance and IT professionals are often asked to do more with less, which can seem overwhelming given an ever-expanding list of regulatory and business requirements as well as increased scrutiny of firms’ cybersecurity controls by third parties.

Why Should a Big Hedge Fund Use a Compliance Consultant?

If your firm isn’t already using an outside consultant, you may want to ask yourself “why not?” Oftentimes at hedge funds, compliance officers struggle to successfully fulfill the requirements of the job without an essential tool in their toolbox: the outside compliance consultant. Why? The primary reason is simple: resources.


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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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