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Annual Review

Three strikes and you’re out. A critical SEC exam best practice is to make sure you address and correct deficiencies previously cited by the Commission and ...
      Investment Company Act of 1940 — Section 12(d)(3) Adams Diversified Equity Fund Inc. April 30, 2015 RESPONSE OF THE CHIEF COUNSEL'S OFFICE ...
It’s right there in black and white in current SEC exam document request letters. Before arriving on-site at an advisory firm, Commission examiners are seeking ...
Believe it or not it’s been more than 10 years since the annual review requirement came into place. While the annual review can seem like ...
These are instructions for how to conduct a transaction analysis for forensic testing around trading. This comes courtesy of Krista Zipfel, CEO/president of Advisor Solutions ...
Every registered unit investment trust shall file an annual report on Form N-SAR with respect to each calendar year not more than sixty calendar days ...
(a) Each registered investment company and business development company (“fund”) must: (1) Policies and procedures. Adopt and implement written policies and procedures reasonably designed to ...
One test to help you assess whether clients are being treated fairly is to examine performance dispersion. Run a report on performance of all client ...
Two years after SEC commissioners failed to advance the case against former Ferris, Baker Watts General Counsel Ted Urban (IA Watch, Feb. 6, 2012), concern ...
Click here to open a Word file that comes from a peer and is called a risk identification questionnaire. Use this tool to help discover ...
It's not uncommon for institutional investors to ask an adviser for copies of its last two annual reviews. "I'm more than happy to show it ...
Click here to download an Excel file that gives you a template for how to display compliance tests and their results for use in your ...
If you've ever questioned the wisdom of e-mail monitoring, consider this story. A CCO searches for the word "offer" and discovers an exchange in which ...
On the basis of this Order and Respondents’ Offers, the Commission finds that: 1. Between January 1, 2007 and September 3, 2009, the relevant time period ...
This matter involves custody rule violations and supervisory and compliance failures at Vector, a Minnesota investment adviser registered with the Commission since 1997.
Some CCOs never appear before their firm's board. In other cases, a board meeting isn't gaveled into order without compliance being seated. You can gain ...
From the time it registered with the Commission in October 2007 until December 2010, IMCAM failed to conduct an annual review of its policies and procedures, ...
Click here to open a Word file that is a risk matrix specifically designed for an adviser to a mutual fund or otherwise operates under ...
Click here to open a Word file, courtesy of Karen Huey of Professional Compliance Assistance in Woodstock, Ga., which is a summary of expectations for ...
Only broad guidelines exist from the SEC on how you should go about your annual review, which is why it pays to hear best practices ...
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