Tag: COVID-19

Breakdown of OCIE’s COVID-19 Compliance Risks Alert

The SEC’s “Office of Compliance Inspections and Examinations (“OCIE”) issued an Alert today regarding “Select COVID-19 Compliance Risks for Investment Advisers and Broker-Dealers.” OCIE shared observations regarding six broad categories: protection of investors’ assets; supervision of personnel; practices relating to fees, expenses, and financial transactions; investment fraud; business continuity; and the protection of investor and … Continued

COVID-19 and Compliance – Mitigation Efforts Will Have Compliance Consequences the SEC Soon Will Examine

We understand that COVID-19 has brought many stresses, both personal and professional.  To many private fund advisers, this may seem an appropriate time to allow “compliance” to take a “back-seat.”  However, many business and management decisions your firm now may be contemplating or is already positioned to take likely will have compliance ramifications, now or … Continued

Where Are Your Cybersecurity Blindspots with COVID-19?

Google Data Reveals 350% Surge In Phishing Websites During Coronavirus Pandemic More financial firms have shifted to a remote workforce in the midst of the COVID-19 pandemic. While the availability of VPNs and cloud-based services has enabled firms to continue operating, the paradigm shift to an entire staff working from home has not come without … Continued

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

Guidance for State-Registered Advisers Dealing with COVID-19

In addition to the SEC providing relief and support to investment advisers, the North American Securities Administrators’ Association (NASAA) and state regulators have also provided guidance in the form of a very helpful resource page. The page includes information on temporary regulatory relief, as well as updates on the operating status of NASAA members. The … 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

SEC Offers Additional Relief for Advisers Impacted by Coronavirus

The SEC has made several COVID-19 related announcements this week pertaining to investment managers that offer relief from routine regulatory obligations. First, the SEC has issued relief in filing due dates and delivery requirements related to the Coronavirus (COVID-19) and the current market conditions. This will extend the reporting deadline 45 days for Forms ADV, … 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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