Investment Advisers Act Rule 206(4) (the “Custody Rule”) is designed to protect client funds and securities from being lost, misused, or otherwise misappropriated by investment advisers. As such, the Custody Rule provides...more
On Tuesday, February 13, 2018 the Securities and Exchange Commission (“SEC”) announced the opening of registration for its compliance outreach program’s national seminar for investment companies and investment advisers, which...more
The Office of Compliance Inspections and Examinations (the “OCIE”) published a Risk Alert on September 14, 2017 discussing the most frequent issues that the OCIE observed during its examinations of investment advisers with...more
On February 21, 2017 the Securities and Exchange Commission (the SEC) released new guidance concerning when a registered investment adviser is deemed to have “custody” for purposes of Adviser’s Act Rule 206(4) (the Custody...more
On August 25, 2016, the Securities and Exchange Commission (the “SEC”) adopted amendments to rules promulgated under the Investment Advisers Act of 1940 (the “Advisers Act”) and the investment adviser registration and...more
In connection with publication of final regulations (the Rule) on the definition of “fiduciary” under the Employee Retirement Income Security Act of 1974, as amended (ERISA) and the Internal Revenue Code of 1986, as amended...more
On April 8, 2016, the United States Department of Labor (Department) published its long-awaited final regulations (the Rule) redefining who is a “fiduciary” of an employee benefit plan under the Employee Retirement Income...more
On February 2, 2016, the U.S. Small Business Administration (SBA) released a Federal Register Call Notice (2016 Call Notice) inviting fund managers to submit preliminary materials in the form of the Management Assessment...more
Small Business Investment Company (SBIC) investment advisers will now have reduced registration requirements under the Investment Advisers Act of 1940 (Advisers Act), thanks to the recently enacted SBIC Advisers Relief Act....more
The Office of Compliance Inspections and Examinations (the OCIE) has just published a new Risk Alert on cyber risks and precautions identifying specific areas it will be focusing on during the second round of examinations of...more
Registered investment advisers should periodically assess their cybersecurity vulnerabilities, create strategies to respond, and make sure they are making the strategies work. ...more
On February 3rd, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission released a summary of its cybersecurity findings during sweep reviews in 2014. ...more