Tag: Rule 206(4)-7

SEC Continues Scrutiny of Private Fund Cross Trades

The SEC continues to scrutinize principal and cross-trade transactions in the private fund world. Are such trades illegal? No. In fact, with sufficient disclosures (and supervisory controls, of course), a private fund adviser can conduct principal and cross trades, which can offer certain benefits to the funds under management. For example, cross trades can be … Continued

Effective Compliance Policies & Procedures and Annual Reviews: Meeting the Reasonably Designed Standards

Sometimes it seems that enough is never really enough. While compliance officers have grown intimately familiar with SEC Rule 206(4)-7 over the past 15 years since the Rule became effective, deficiencies in connection with the Compliance Program Rule continue to rank among the most frequently cited issues identified in OCIE examinations of investment advisers. It … Continued

Refreshing the Annual Review Process to Address Business and Regulatory Risks

Rule 206(4)-7 requires each registered adviser to review its policies and procedures no less frequently than annually, to determine their adequacy and the effectiveness of their implementation. But what’s the best way to approach this review? How are other firms meeting this requirement? At the recent Ascendant Compliance Solutions Strategies 2019 Spring Conference in Miami … Continued


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