Tag: Coronavirus

SEC Grants Section 17a No-Action Relief to Open-End Funds

The SEC has taken many actions in the past month to provide relief to registrants and the financial services industry during the COVID-19 national emergency. Another recent action is the relief granted by the SEC to open-end investment companies that are not exchange-traded funds and are not considered money market funds (“Funds”). The relief, granted … Continued

SEC Extends Form ADV & Form PF Relief, Modifies Conditions

On March 25, 2020, the SEC issued a new Order extending and relaxing some of the conditions pertaining to the available relief for filing and delivering Form ADV amendments and for filing Form PF.  Under the new Order, which replaces the March 13 Order, the relief is extended to applicable filing and delivery obligations on … Continued

OCIE Now Conducting Exams Off-Site Unless Necessary

On March 23, 2020, the SEC’s Office of Compliance Inspections and Examinations posted an announcement on its website that “in light of health and safety concerns and other circumstances, OCIE has moved to conducting examinations off-site through correspondence, unless it is absolutely necessary to be on-site.” Similarly, over recent weeks, CSS has arranged with clients … Continued

CTFC Issues No-Action Letters for Temporary Relief in Response to COVID-19 Pandemic

During the last week, the CFTC issued several no-action letters aimed at providing temporary relief from certain recordkeeping, operations requirements, and some reporting deadlines as summarized in the table below. In addition, the CFTC offers a coronavirus-focused webpage, cftc.gov/coronavirus, which includes eight of the nine No-Action letters as well as a Customer Advisory to raise … 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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