The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers -
The Securities and Exchange Commission (“SEC”) and the...more
5/24/2024
/ AML/CFT ,
Bank Secrecy Act ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Notice of Proposed Rulemaking (NOPR) ,
Popular ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC)
Section 3(a)(5) of the Securities Exchange Act of 1934, as amended (the “Securities Exchange Act”) defines a “dealer” as “any person engaged in the business of buying and selling securities […] for such person’s own account...more
On March 3, 2021, the SEC’s Division of Examinations (“Division” or “EXAMS”) published its annual Examination Priorities Report, which identified eight primary areas of focus for Fiscal Year 2021. While many of these...more
4/1/2021
/ Anti-Money Laundering ,
Broker-Dealer ,
Coronavirus/COVID-19 ,
Digital Assets ,
Environmental Social & Governance (ESG) ,
FinTech ,
Fraud ,
Information Security ,
Investment Adviser ,
Libor ,
Market Infrastructure ,
Regulation Best Interest ,
Retail Investors ,
Securities and Exchange Commission (SEC)
SEC Enforcement and Exams Likely to Focus More on Private Funds in the New Administration -
For the next several weeks and months, intense focus will be trained on determining the priorities of the Biden administration. We...more
2/2/2021
/ Annual Reports ,
Biden Administration ,
Confidential Information ,
Conflicts of Interest ,
Coronavirus/COVID-19 ,
Cybersecurity ,
EBITDA ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Fees ,
Investigations ,
Investment Adviser ,
Investment Companies ,
Private Funds ,
Ransomware ,
Risk Alert
In recent years, the U.S. Securities and Exchange Commission’s Office of Inspections and Examinations (“OCIE”) has prioritized, in its examinations, the review of the fee billing and expense practices of investment advisers....more
In early January, both the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) and FINRA announced their examination priorities for 2017. As in previous years, both the SEC and FINRA share many examination...more