OCIE Observations: Compliance Programs

OCIE Observations: Compliance Programs

04 January 2021

Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant   The SEC Risk Alerts keep coming, this time with exam observations regarding investment advisors’ Compliance Programs. According to OCIE, the most common exam deficiencies arise from issues with Rule 206-4(7), known as “the Compliance Rule.” Rule 206(4)-7 requires investment advisors to have policies andRead More »

SEC Risk Alert: Safeguarding Against Credential Compromise

SEC Risk Alert: Safeguarding Against Credential Compromise

30 October 2020

Main Contributor: Gretchen Sturdivan, Creative Director & Client Service Manager   On September 15th, the SEC issued a Risk Alert to address a method of cyber-attack that is more sophisticated yet increasingly accessible to attackers: “credential stuffing.” We’re getting close to Thanksgiving, but that’s not the direction the SEC is going. This method of cyber-attackRead More »

SEC Amendments to the Accredited Investor Definition

SEC Amendments to the Accredited Investor Definition

24 September 2020

Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant   In August of this year, the SEC released an amendment to the “accredited investor” definition. What is an Accredited Investor? Certain qualifications must be met in order to invest in private placements or private funds. One qualification is being an “accredited investor.” An accreditedRead More »

SEC Risk Alert: Form CRS

SEC Risk Alert: Form CRS

08 May 2020

Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant   SEC Risk Alert: Form CRS On April 7, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) issued a risk alert to let advisors and broker-dealers know that, regardless of COVID-19,  it’s business as usual at the SEC and firms must continue to meetRead More »

Cryptocurrencies… are they considered a security?

Cryptocurrencies… are they considered a security?

03 January 2018

SEC Chairman Jay Clayton recently issued a statement about the highly discussed topic of cryptocurrencies and initial coin offerings (ICOs) on December 12, 2017. He addressed main street investors and market professionals, which includes investment advisers and broker-dealers, among others. Clayton warned market professionals to review SEC investigative reports and subsequent enforcement actions. The conclusionRead More »