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The ICI believes that the relief outlined herein is necessary to enhance the liquidity and stability of money market funds during the ongoing and significant ...
DB Fitzpatrick “terminated the chief compliance officer at the time of the Contributions and hired a new chief compliance officer
The three allegedly altered and withheld documents after OCIE examiners commenced an exam in 2016
The order, tied to the coronavirus, also extends to Form PF filings
Strings attached if you wish to delay filing Forms ADV and PF
You may not include disclosure in the relationship summary other than disclosure that is required
The SEC has been reaching out to firms to talk about COVID-19
IAs and B-Ds would have to have “sufficient information to evaluate an Offeree’s financial circumstances and sophistication
Industry comments signal an organized campaign to deluge the SEC and steer the regulator away from going through with proscribed compliance due diligence steps
ESG is hotter than ever, and regulators have noticed the trend
We are proposing to modernize and simplify the Securities Act integration framework for registered and exempt offerings
The NFA encourages members to review their BCPs and to include the prospect of a pandemic in their plans
compliance staff failed to create P&Ps to ensure that reps were being monitored when placing clients in inverse ETFs
Adjusting or building upon current systems of supervision/compliance an option
“Congress has never given the SEC authority to seek and obtain an order of disgorgement from a district court”
“Just start drafting. Start typing. The longer you wait to start the drafting process, the more challenging it’s going to be”
Be aware that examiners may question your logic for placing clients in certain share classes
“If you’re going to save this industry, you’re going to have to do a 180-degree turn"
The SEC gives the nod of approval for an investment adviser and its affiliated IA to create one form
Testimonials “will lead to a race to the bottom - once the market is opened to these types of endorsements, investor confusion will increase dramatically"

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