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Investment Adviser Regulatory Oversight Chief Compliance Officers

Proskauer Rose LLP

SEC Cites Falsified Compliance Records in Two Recent SEC Settlements with CCOs

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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

SEC Compliance Consultants, Inc. (SEC³)

Tips for Updating Your Compliance Program in 2025

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

SEC Compliance Consultants, Inc. (SEC³)

Write the Best Annual Compliance Review Ever!

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

Faegre Drinker Biddle & Reath LLP

FINRA Wades into the Controversial Deep-End of CCO Supervisory Liability

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

Faegre Drinker Biddle & Reath LLP

NYC Bar Association Proposes a CCO Enforcement Framework

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

Foley & Lardner LLP

Lessons Learned From OCIE’s Inspections of Investment Adviser Compliance Programs

Foley & Lardner LLP on

The Office of Compliance Inspections and Examinations (OCIE) issued a risk alert on November 19, 2020 related to the Advisers Act compliance rule, Rule 206(4)-7. Some key takeaways for Chief Compliance Officers (CCOs) are as...more

Proskauer Rose LLP

Regulation of Custodial Practices Under the Investment Advisers Act of 1940 Rule 206(4)-2: October 2019

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Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...more

Herbert Smith Freehills Kramer

Funds Talk: March 2017

OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more

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