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By Ian Meiksins, Key Bridge Compliance President The Securities and Exchange Commission proposed a new rule that would require registered investment advisors to conduct due diligence and ongoing review of a vast array of third-party service providers. The proposed rule is coming at a time where...
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By Kevin Kirk On March 30, 2022, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“Division”) released its 2022 Exam Priorities. The stated purpose for the Division in releasing these priorities is to promote compliance, prevent fraud, identify and monitor risk,...
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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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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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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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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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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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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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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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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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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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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
By Ian Meiksins, Key Bridge Compliance President The Securities and Exchange Commission proposed a new rule that would require registered investment advisors to conduct due diligence and ongoing review of a vast array of third-party service providers. The proposed rule is coming at a time where...
Read More
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
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
By Kevin Kirk On March 30, 2022, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“Division”) released its 2022 Exam Priorities. The stated purpose for the Division in releasing these priorities is to promote compliance, prevent fraud, identify and monitor risk,...
Read More
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
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
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
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
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
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
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...
Read More
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...
Read More