ACA Group’s Lessons Learned and thought leadership:

• Failure to Follow the Rules Can Be Costly
• “Does Your Company Need a ChatGPT Policy? Probably”. Chat GPT is a certainly a hot topic. The New York University School of Law’s Program on Corporate Compliance and Enforcements raises thoughtful considerations.
• Communicating with the SEC When Your Organization Suffers a Cybersecurity Incident. MoFo (Morrison Foerster) provides some tips about when to proactively report hacking incidents to the SEC.
• NYDFS Issues Guidance on Virtual Currency Custody Practices. For those following the evolving virtual currency custody environment, Dechert’s Financial Services Group recently addressed the New York Department of Financial Services’ (NYDFS) guidance.
• The DOL’s New Fiduciary Rule: What We Can Expect. Fred Reish and Joan M. Neri of Faegre Drinker weigh in on the DOL’s anticipated new fiduciary rule proposal.

Additional thought leadership and Insights can be found here.

From Morgan Lewis’ LawFlash, the SEC’s division of Investment Management’s announcement that it would allow its October 26, 2017 no-action letter to SIFMA to expire on July 23, 2023 “pulls the rug out from under ‘Hard Dollar’ research arrangements,” and raises questions about the possible investment adviser status of broker-dealers that, after that date, accept cash or “hard dollar” payments for research from investment managers subject to the EU Markets in Financial Instruments Directive II.

Read more here.

From our friends at Hardin Compliance Consulting LLC, helpful guidance for broker dealers and RIAs, as they plan their return:

• Question & Answer Employer Guide: Return to the Work in the time of COVID-19 by Faegre Drinker.
• Making your Office Safe to Return after COVID-19 by Riia O’Donnell of Workest.
• Preparing for Reentry in the US by Goodwin Procter LLP.
• Reopening Your Doors – BakerHostetler’s Return to Work Toolkit