News & Analysis as of

Securities and Exchange Commission (SEC) Regulatory Requirements 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

Ropes & Gray LLP

Overview of ETF Share Class Operational Issues

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One of the most talked about topics in asset management is the possibility of offering Mutual Fund and ETF Classes in the same Fund. It appears that Funds may obtain the Relief necessary to offer these Share Classes in the...more

SEC Compliance Consultants, Inc. (SEC³)

7 Ugly Truths About Compliance: A Primer for New Chief Compliance Officers

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

NAVEX

Compliance Program Response to the Incoming Trump Administration

NAVEX on

How should my compliance program prepare for the Trump administration? This is a question I have been asked a lot over the past few weeks. And as we start a new year and a second Trump administration that promises to be a...more

Bass, Berry & Sims PLC

[Webinar] ESG Outlook: Preparing for the 2025 Reporting Season - December 17th, 12:00 pm - 1:00 pm CST

Bass, Berry & Sims PLC on

Join Bass, Berry & Sims and leading environmental, social, and governance (ESG) along with corporate and securities thought leaders for the next installment of our ESG Impact Webinar series. As public companies prepare for...more

Society of Corporate Compliance and Ethics...

Albemarle: One year later

I had many ideas for an article that would expand on recent developments in the compliance and ethics space. My working title was the creatively light “Recent Developments.” But after meeting with SCCE & HCCA’s editorial...more

SEC Compliance Consultants, Inc. (SEC³)

How Much Testing is Enough?

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

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - November 7th, 8:00 am - 5:00 pm CT

Stay on top of ever-evolving ESG requirements and emerging trends - With the SEC’s newly issued rules surrounding ESG disclosures and the continued growth of regulations rolling out in the EU, Canada, Asia and elsewhere...more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - March 28th, Phoenix, AZ

Looking for compliance training and networking in your area? SCCE’s Regional Compliance & Ethics Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

Thomas Fox - Compliance Evangelist

Prudent discharge of compliance obligations by a Board

What are the obligations of a Board member regarding the Foreign Corrupt Practices Act (FCPA)? Are the obligations of the Compliance Committee under the FCPA at odds with a director’s “prudent discharge of duties to...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

Mayer Brown Free Writings + Perspectives

SEC Permits Fund Board Reliance on CCOs

On October 12, 2018, the Securities and Exchange Commission’s Division of Investment Management issued a no-action letter permitting a fund’s board of directors (“Board”) to rely upon quarterly compliance certifications...more

Herbert Smith Freehills Kramer

SEC Staff Allows Boards to Rely on CCO Determinations for Various Affiliated Transactions

In a no-action letter (the Relief) issued on Oct. 12, 2018, to the Independent Directors Council, the Securities and Exchange Commission staff (the Staff) confirmed that they would not recommend enforcement if a fund’s board...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

U.S. Financial Industry Developments - SEC Disapproves the Listing and Trading of Nine Bitcoin Related Exchange Traded Products - On August 22, 2018, the SEC released three Orders, acting through authority delegated to...more

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