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PART I: Addressing Recent OCIE Risks—Inadequate Compliance Resources

Dec 7, 2020

PART I: Addressing Recent OCIE Risks—Inadequate Compliance Resources

Author: Amy D’Avella This is the first in a series of blogs which will analyze the SEC’s Office of Compliance Inspections & Examination’s (OCIE) November 19 Risk Alert, titled OCIE Observations: Investment Adviser Compliance Programs.[1] I. Context Since requiring investment advisers...

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Risk Alert: OCIE Releases Risk Alert Targeting CCOs and Compliance programs

Nov 23, 2020

Risk Alert: OCIE Releases Risk Alert Targeting CCOs and Compliance programs

Coinciding with the SEC’s annual Compliance Outreach Program National Seminar, on November 19 the Office of Compliance Inspections & Examinations (OCIE) released a risk alert titled OCIE Observations: Investment Adviser Compliance Programs. This is the first risk alert in five years specific...

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OCIE Risk Alert - Multi-Branch Offices

Nov 10, 2020

OCIE Risk Alert - Multi-Branch Offices

On November 9, 2010, the Securities and Exchange Commission’s Office of Examinations and Inspections released a risk alert titled Observations from OCIE’s Examinations of Investment Advisers: Supervision, Compliance and Multiple Branch Offices. With focus on compliance programs, supervision,...

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The SEC Updates Form CRS FAQs

Oct 19, 2020

The SEC Updates Form CRS FAQs

In the wake of an investigation by the Wall Street Journal showing that 20% of firms incorrectly stated having no disciplinary history in their Form CRS, the SEC updated its Form CRS FAQ on October 8 to clarify this particular reporting requirement. The FAQs illuminate questions 11 and 4 with the...

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New Phishing Scheme Posing as FINRA

Oct 6, 2020

New Phishing Scheme Posing as FINRA

Author: Amy D’Avella Key Bridge Compliance has been made aware of a new phishing attack against both FINRA members and SEC-registered investment advisers. The phishing email appears to be sent from FINRA and attempts to elicit confidential firm information (see representative email below). We...

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SEC Expands Definition of Accredited Investor

Sep 21, 2020

SEC Expands Definition of Accredited Investor

Author: Amy D’Avella Accredited investors are those the SEC deems sufficiently sophisticated to operate in riskier investment environments, such as private markets. This definition has long been limited to select entities and individuals who meet certain net worth requirements. On August 26,...

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OCIE Cybersecurity Risk Alert

Sep 17, 2020

OCIE Cybersecurity Risk Alert

Author: Amy D’Avella On September 15, 2020, the Office of Compliance Inspection & Examinations (OCIE) issued a Risk Alert titled Cybersecurity: Safeguarding Client Accounts against Credential Compromise, warning of a type of cyberattack called “credential stuffing.” Using stolen...

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SEC Releases COVID-19 Risk Alert for Brokers and Advisors

Aug 14, 2020

SEC Releases COVID-19 Risk Alert for Brokers and Advisors

Author: Brian DeChow On August 12th, the Office of Compliance Inspections and Examinations (“OCIE”) issued a risk alert highlighting a variety of compliance issues that the COVID-19 pandemic may have impacted. The observations and recommendations fall broadly into six categories: (1) protection...

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The SEC Releases New Guidance for Advisors Voting Proxies

Jul 24, 2020

The SEC Releases New Guidance for Advisors Voting Proxies

Author: Chris Payne Yesterday, the SEC adopted new rules surrounding proxy advisory firms and provided supplemental guidance for investment advisers to follow. As a result of these new rules, investment advisers who have agreed to take on proxy voting authority on behalf of their clients will be...

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SEC Proposes Increased Threshold for 13F Reporting

Jul 15, 2020

SEC Proposes Increased Threshold for 13F Reporting

Author: Ian Meiksins The SEC has proposed a substantial leap in the reporting threshold of Form 13F. Form 13F, as it currently stands, requires advisors who manage $100 million or more in exchange trade equities to publicly disclose their holdings. The SEC’s new proposal would move the $100...

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The SEC Continues to Put Private Fund Advisers on Notice

Jul 8, 2020

The SEC Continues to Put Private Fund Advisers on Notice

Author: Chris Payne On June 23rd, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert[1] intended to highlight the compliance issues observed during recent examinations of registered investment advisers that manage private equity funds or hedge...

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The Importance of Books and Records in a Bear Market

Jun 9, 2020

The Importance of Books and Records in a Bear Market

Maintaining proper books and records is a key component of your compliance program, but with so many rules and regulations to keep track of it can quickly become complicated. The current environment and the increase in working from home has added further complications to books and records...

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OCIE Risk Alert - Multi-Branch Offices

Nov 10, 2020

OCIE Risk Alert - Multi-Branch Offices

On November 9, 2010, the Securities and Exchange Commission’s Office of Examinations and Inspections released a risk alert titled Observations from OCIE’s Examinations of Investment Advisers: Supervision, Compliance and Multiple Branch Offices. With focus on compliance programs, supervision,...

Read More
New Phishing Scheme Posing as FINRA

Oct 6, 2020

New Phishing Scheme Posing as FINRA

Author: Amy D’Avella Key Bridge Compliance has been made aware of a new phishing attack against both FINRA members and SEC-registered investment advisers. The phishing email appears to be sent from FINRA and attempts to elicit confidential firm information (see representative email below). We...

Read More
The SEC Continues to Put Private Fund Advisers on Notice

Jul 8, 2020

The SEC Continues to Put Private Fund Advisers on Notice

Author: Chris Payne On June 23rd, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert[1] intended to highlight the compliance issues observed during recent examinations of registered investment advisers that manage private equity funds or hedge...

Read More
The Importance of Books and Records in a Bear Market

Jun 9, 2020

The Importance of Books and Records in a Bear Market

Maintaining proper books and records is a key component of your compliance program, but with so many rules and regulations to keep track of it can quickly become complicated. The current environment and the increase in working from home has added further complications to books and records...

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Chris Payne Named Managing Director of Key Bridge Compliance

Sep 30, 2019

Chris Payne Named Managing Director of Key Bridge Compliance

Key Bridge Compliance is excited to announce the promotion of our colleague Chris Payne to Managing Director. Chris joined Key Bridge Compliance in August as part of the acquisition of Graydon Compliance Solutions, where he had been serving as a Chief Compliance Officer since April 2018. Chris has...

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The SEC Updates Form CRS FAQs

Oct 19, 2020

The SEC Updates Form CRS FAQs

In the wake of an investigation by the Wall Street Journal showing that 20% of firms incorrectly stated having no disciplinary history in their Form CRS, the SEC updated its Form CRS FAQ on October 8 to clarify this particular reporting requirement. The FAQs illuminate questions 11 and 4 with the...

Read More
SEC Expands Definition of Accredited Investor

Sep 21, 2020

SEC Expands Definition of Accredited Investor

Author: Amy D’Avella Accredited investors are those the SEC deems sufficiently sophisticated to operate in riskier investment environments, such as private markets. This definition has long been limited to select entities and individuals who meet certain net worth requirements. On August 26,...

Read More
OCIE Cybersecurity Risk Alert

Sep 17, 2020

OCIE Cybersecurity Risk Alert

Author: Amy D’Avella On September 15, 2020, the Office of Compliance Inspection & Examinations (OCIE) issued a Risk Alert titled Cybersecurity: Safeguarding Client Accounts against Credential Compromise, warning of a type of cyberattack called “credential stuffing.” Using stolen...

Read More
SEC Releases COVID-19 Risk Alert for Brokers and Advisors

Aug 14, 2020

SEC Releases COVID-19 Risk Alert for Brokers and Advisors

Author: Brian DeChow On August 12th, the Office of Compliance Inspections and Examinations (“OCIE”) issued a risk alert highlighting a variety of compliance issues that the COVID-19 pandemic may have impacted. The observations and recommendations fall broadly into six categories: (1) protection...

Read More
The SEC Releases New Guidance for Advisors Voting Proxies

Jul 24, 2020

The SEC Releases New Guidance for Advisors Voting Proxies

Author: Chris Payne Yesterday, the SEC adopted new rules surrounding proxy advisory firms and provided supplemental guidance for investment advisers to follow. As a result of these new rules, investment advisers who have agreed to take on proxy voting authority on behalf of their clients will be...

Read More
SEC Proposes Increased Threshold for 13F Reporting

Jul 15, 2020

SEC Proposes Increased Threshold for 13F Reporting

Author: Ian Meiksins The SEC has proposed a substantial leap in the reporting threshold of Form 13F. Form 13F, as it currently stands, requires advisors who manage $100 million or more in exchange trade equities to publicly disclose their holdings. The SEC’s new proposal would move the $100...

Read More
Regulation Best Interest (Reg BI) Update

Sep 24, 2019

Regulation Best Interest (Reg BI) Update

Authors: Jay Kasting and Chris Payne What is Regulation Best Interest On June 5th, 2019, the Securities & Exchange Commission (SEC) finally unveiled the much talked about Regulation Best Interest, also known as “Reg BI.” The new rule comes on the heels of the vacated “Fiduciary...

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