Our Blog

Dec 7, 2020

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...

Nov 23, 2020

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...

Nov 10, 2020

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,...

Oct 19, 2020

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...

Oct 6, 2020

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...

Sep 21, 2020

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,...

Sep 17, 2020

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...

Aug 14, 2020

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...

Jul 24, 2020

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...

Jul 15, 2020

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...

Jul 8, 2020

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...

Jun 9, 2020

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...