Compliance into the Weeds: The Dark Side of AI in Employee Training
What to Do When Leadership Doesn’t Take Compliance Seriously
Compliance Tip of the Day - The ROI of Compliance
Moving Beyond the Usual Helpline Data
Avoiding a Bored Board
Compliance Tip of the Day: Compliance Responses to Design Intelligence
Compliance Tip of the Day: Avoiding CCO Liability
#Risk New York Speaker Series: Exploring AI Risks in Compliance with Gwen Hassan
Everything Compliance: Episode 155, To Tesla and Beyond Edition
Great Women in Compliance: Culture. Data. Ethics with Hui Chen
Compliance Amidst a Global Consensus Breakdown
Great Women in Compliance – Compliance is the Floor, Ethics is the Ceiling with Ellen Hunt
Innovation in Compliance: Innovative Approaches to Compliance and Training with Catherine Choe
FCPA Compliance Report: Upping Your Game in Compliance
Compliance Tip of the Day: Empowering Middle Managers to Drive Compliance Transformation
Creativity and Compliance: From Compliance Enforcers to Trusted Advisors: The Path Forward
Compliance Tip of the Day: Middle Managers as the Eyes and Ears of Compliance
Great Women in Compliance: Exploring the Future of Compliance - Key Takeaways from Compliance Week 2025
Mistakes Lawyers Should Avoid When Moving into Compliance
Innovation in Compliance: Exploring the Fractional COO Model with La Tonya Roberts
Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding...more
Many compliance officers live in hope that if they ramp up their persuasive skills, engage employees with spectacular training presentations, and provide succinct and prompt advice, they will receive the respect and...more
Who may be interested: Registered Investment Companies; Investment Advisers; Boards of Directors; Compliance Officers - Quick Take: The SEC recently announced a six-month extension of the compliance dates for amendments to...more
In addition to basic blocking and tackling, compliance officers often have the thankless job of performing the annual review of their compliance program required by Advisers Act Rule 206(4)-7....more
On August 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements regarding “off-channel communications.”1 As part of its Off-Channel Communications Initiative,2 the SEC settled...more
Who may be interested: Registered Investment Companies; Boards of Directors; Investment Advisers; Compliance Officers; Fund Administrators- Quick Take: In its August 28, 2024, open meeting, the SEC amended fund reporting...more
Most compliance officers struggle to determine whether they are conducting enough testing to satisfy their obligations under the Advisers Act. In its release adopting Advisers Act Rule 206(4)-7, the SEC stated that an...more
SEC’s Division of Examinations (“EXAMS”) issued a risk alert on its Initial Observations Regarding Advisers Act Marketing Rule Compliance (the “Risk Alert”), giving compliance officers an unexpected gift by sharing examples...more
Many chief compliance officers struggle every year with preparing the annual review required under Advisers Act Rule 206(4)-7. To help you out, here’s our guide to writing your annual report....more
There are times when it makes sense to hire an expert. Securities regulations are complicated, and failure to comply can be costly, both in terms of fines and damage to reputation. Here are the top reasons registered...more
Who may be interested: Boards of Directors, Investment Advisers, Compliance Staff - Quick Take: The SEC proposed Rule 3c-7 under the 1940 Act, which would inflation adjust the dollar threshold for a fund to meet the...more
On December 5, 2022, the SEC filed a settled action against investment advisory firm Two Point Capital Management Inc. (the Firm) and its chief executive officer, who also served as the Firm’s chief compliance officer until...more
The compliance date for the SEC’s new investment adviser Marketing Rule is November 4, 2022, allowing just over a month for an investment adviser to finalize its implementation process to comply with the Rule, which applies...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important U.S. Securities and Exchange Commission (SEC) enforcement developments from the past month,...more
On April 26, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) issued a risk alert concerning deficiencies related to Section 204A of the Investment Advisers Act of 1940 (“Advisers...more
On April 26, 2022, the SEC’s Division of Examinations (“EXAMS”) issued a risk alert flagging certain notable deficiencies that it has observed related to advisers’ potential misuse of material non-public information (MNPI) in...more
I attended the four-day SIFMA Compliance and Legal seminar last week, and there were a bunch of interesting soundbites from regulators that folks might find interesting. The challenge at these conferences is always...more
The lack of specific guidance regarding failure to supervise liability for chief compliance officers (“CCOs”) has been a controversial and opaque topic that both FINRA and the SEC have struggled with for well over a decade....more
Rule 38a-1 under the Investment Company Act of 1940 (the 1940 Act) requires funds to review their compliance programs, as well of those of their service providers, including their investment advisers (advisers), annually....more
The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: An Overview - This article is an overview of the requirements of PTE 2020-02. It discusses the expanded fiduciary definition, the conditions in the PTE, and the...more
Responding to a “concern” from Chief Compliance Officers (CCOs) to the purported increase in enforcement actions holding compliance personnel personally liable, the New York City Bar Association recently released a framework...more
Summaries of recent legislative and regulatory developments with respect to: •The SEC’s Examination Priorities for 2021- •The SEC’s Focus on Digital Asset Securities- •The SEC’s New Marketing Rule... ...more
In November 2020, the staff of the SEC’s Division of Examinations (f.k.a. OCIE) (the “Examinations Division” and its staff, “Examinations Staff”) issued two risk alerts (the “Alerts”) that, in our view, offer particularly...more
A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more
The SEC's Division of Examinations recently issued a Risk Alert with observations on investment adviser compliance programs, noting numerous deficiencies and weaknesses it has encountered....more