Tag: SEC

SEC Reopened After 35-Day Government Shutdown

SEC Chairman Jay Clayton announced on Saturday, January 26 that with an agreement reached to end the government shutdown, the “Commission has resumed normal staffing levels and is returning to normal operations.” In total, about 94% of the commission’s approximately 4,400 employees had been furloughed during the 35-day shutdown, according to its operations plan. In a … Continued

SEC OCIE Issues 2019 Examination Priorities

Well ahead of the New Year, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2019 examination priorities. In keeping with OCIE’s four “pillars” of promoting compliance, preventing fraud, identifying and monitoring risk, and informing policy, the Dec. 20 release provides a preview of key areas where OCIE intends to focus its limited … Continued

How Do You Supervise for SEC Pay-to-Play Violations?

If you wanted more information about the contours of the SEC’s Pay-to-Play Rule, or how the SEC may enforce it, three recent Settlement Orders against large investment advisers for “over de minimis” political contributions provide some insight regarding one of the prohibitions: Contributions by Covered Associates to certain Government Officials over the specified Exception amount (capitalized words are terms in the … Continued

Do Your Fund Documents Clearly Disclose Receipt of Accelerated Monitoring Fees?

Somewhat more reminiscent of the broken-windows enforcement era, two affiliated private equity advisers managing billions settled with the SEC on charges that they failed to make pre-commitment disclosures in fund governing documents related to accelerated fees received from portfolio companies. Interestingly, according to the Settlement Order, the advisers had made some disclosures in fund documents … Continued

With New Risk Alert, SEC Doubles Down on Best Execution

On July 11, 2018, the SEC issued a Risk Alert outlining commonly found compliance issues related to best execution by investment advisers. Advisers have an obligation to seek best execution of client transactions, taking into consideration quantitative factors such as execution quality and commission rate, as well as more qualitative factors such as the value … Continued

For Cryptocurrency and Blockchain, a Reckoning is Coming

 NOTE: Ascendant Director of Cyber IT Services E.J. Yerzak recently spoke at the AIM Summit in Abu Dhabi, a conference that targets alternative investment managers. The following is a brief summary of his key comments during his two sessions, “Primer on Crypto Currency, Distributed Ledger Technology and ICO’s,” and “Legal & Regulatory Insights/AML – Blockchain” … Continued

Tech Transforms Compliance Role in 2017

CSS Chief Regulatory Officer Jeanette Turner was quoted in a recent Ignites article on how “Tech Transforms Compliance Role in 2017.” A flood of new reporting requirements and a shift in regulators’ expectations has made technology a critical component of fund companies’ compliance work in 2017. Chief Compliance Officers’ use of technology “is no longer … Continued

The SEC Data Breach And Impact On New Reporting Rules

The U.S. Securities and Exchange Commission disclosed recently that its Electronic Data Gathering, Analysis and Retrieval (EDGAR) system, a comprehensive database of filings by public companies and other industry participants, was hacked in 2016 and that the intruders may have traded on the information. The announcement comes on the heels of the mutual fund industry … 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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