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Oxbow did not adequately disclose all material facts regarding the conflict of interest that arose when it invested advisory clients in a share class that ...
'Reasonable efforts' to verify the information should occur no later than June 30
Sherlock Holmes famously solved a case by listening for a dog that didn’t bark. Since the early days of the coronavirus crisis, a deafening silence ...
The SRO will take the same approach outlined in the Commission's two risk alerts
Private funds will be the subject of their own separate risk alert later this year, OCIE Director Pete Driscoll says. “That’s something we’ve been getting ...
Be aware that examiners may question your logic for placing clients in certain share classes
“Take your time in producing your data” to examiners, recommends a CCO
Get the jump on your next exam
Prepare now if you’re at a larger CPO for the potential of a CFTC exam next year. The visit would be separate from whatever the ...
Eyes are peering upon a draft that could eventually become the SEC’s proposed new IA advertising rule. In yet another sign that a long-awaited proposal ...
It’s expected that the promised revision to the Advisers Act’s nearly 60-year-old advertising rule will address social media. That insight came out of a recent ...
 Investment advisers are struggling with disclosure rules tied to agency cross trades, and when selling or buying securities from their clients—especially when pooled investments are ...
Our recap of recent SEC exam activity includes three new document request letters obtained by RCW (IA Watch, Aug. 1, 2019). The first exam letter dives ...
OCIE examiners visited the mutual fund adviser with one goal: to assess if the fees it receives for shareholder services were legit. “If you’re collecting ...
OCIE Exam Priorities - Regulatory Compliance Watch
Sometimes predictions come true. Several CCOs report to RCW that their OCIE exams have stretched out due to the government’s record long shutdown earlier this ...
You’re at a small firm and examiners are coming in. What are the issues they are most likely to surface, and what’s the best way ...
OCIE Exam Priorities - Regulatory Compliance Watch
Summertime and the living is easy, but that’s not why this is an exciting time for the SEC’s Alicia Tate. “It’s my favorite time of ...
The SEC’s mum about its “upgrade” to how advisers can upload to OCIE materials requested by examiners.   The new system, called Kiteworks, was due ...
At least at its annual conference, FINRA goes all out to keep its customers happy. A survey of last year’s event, for example, found one ...
Retail investors likely would never think to ask to read an adviser’s deficiency letter from the firm’s most recent OCIE exam. But institutional investors aren’t ...
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