Whitepapers

Practical Trade Desk Oversight

When people think of an Investment Adviser, their first notion would likely be of the trading desk. The desk is where the “rubber meets the road” in the investment world. All other activities within the IA serve to support trading activity and the selection of one investment possibility over another. It is on the trading … Continued

Pressures and Changes Around SEC Examinations

Since the Madoff Ponzi scheme unraveled, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has been under the microscope. Wide criticism has been leveled about how the SEC has selected advisers for examination and how the SEC conducts examinations of investment advisers. The SEC’s responses have included new examination initiatives (primarily involving third-party asset verification of client funds and … Continued

Records Management for Investment Advisers

An investment adviser posts a seemingly innocuous comment to his firm’s social networking profile page, congratulating his colleagues on a successful year selecting investments. Another adviser, upon realizing that one of her long-time clients has recently moved and did not receive the firm’s new Form ADV brochure, quickly sends an e-mail to the client and attaches the requested documents.

Considerations for Outsourcing Compliance

In the post-Dodd-Frank regulatory world, investment advisers seeking to meet the expectations of the Securities and Exchange Commission (“SEC”), or of other regulators, face a common challenge: How do we manage our business, stay on top of all the regulatory requirements and changes, and still meet our day-to-day compliance responsibilities? This article discusses the factors investment adviser firms must consider when determining … Continued

Friend-ing Social Media: Considerations for Investment Advisers Use of Social Media Networks

Technology has quickly infiltrated all aspects of our lives. Whether it’s built-in GPS technology in mobile devices or the proliferation of applications that help us shop for groceries, technology is everywhere. According to Nielsen’s “State of the Media: The Social Media Report — Q3 2011” study, social networks and blogs continue to dominate Americans’ time online, and Americans spend more time … Continued

Supervisory Liability and Compliance: The Risk-Oversight Tradeoff

Compliance is a unique and somewhat paradoxical professional responsibility – one that must simultaneously co-exist in a silo of independence and as a fly on the wall of each department within investment advisory and broker-dealer firms. While some employees may believe that compliance personnel are constantly after them with an onslaught of regulatory requirements, acknowledgement … Continued

What a Difference a Year Makes: Best Practices for Completing Form ADV

The anniversary filing of the revamped Form ADV Part 1A, which included material changes to the Part 2A brochure, is thankfully behind us. The “Annual Updating Amendment” was filed by April 1st this year (2013), for the majority of registered SEC1 advisers, Exempt Reporting Advisers, and new private fund advisers. The industry wrestled with the … Continued

Practical IT Change Management, the CCO’s Best Friend: Utilizing Change Management to Evidence Monitoring

Utilizing Change Management to Evidence Monitoring As the SEC arrives to the technology party in a very public manner, investment advisers and broker dealers, who have already been operating in a needs-driven and best practice environment, must now open their programs for scrutiny. Current SEC and FINRA exams are already extending the interview and examination process … Continued

Robust Product Due Diligence: It’s A Necessity, Not an Option!

New product offerings continue to proliferate as Wall Street strives to meet consumer demand. What is driving this process? Among other factors, today’s low interest rate environment has all investors chasing yields into potentially unknown territory, perhaps without fully understanding all of the risks involved. Increasingly, institutional investors, who are generally sophisticated investors experienced at … Continued

Like It Or Not: Social Media and the Testimonial Rule

Social media took center stage again when the Division of Investment Management of the Securities and Exchange Commission (“SEC”) released long awaited guidance on the applicability of the testimonial rule under the Advisers Act to the growing use of social media by investment advisers. But is it the Liberty Bell of social media freedom ringing … 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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