February Regulatory Updates from Jaqueline Hummel at Hardin Compliance Consulting LLC.

Topics include:

• OCIE Announces 2019 Examination Priorities
• Regulatory Review 2018
• 11 Key Takeaways for Updating your Compliance Program in 2019
• Investment Advisers Compliance to Do List for 2019
• FINRA Provides Additional Guidance to Enhance your Cybersecurity Program
• Broker-Dealer Compliance to Do List for 2019
• Broker-Dealer 2018 Regulatory Year in Review
• Broker-Dealers! Be Sure to Whitelist noreply@finra.org
• 2019 Annual Entitlement User Accounts Certification Process
• FINRA 2019 Annual Risk Monitoring and Examination Priorities Letter FINRA
• NFA Members Need to Update Cybersecurity Programs
• CPOs required to Implement Internal Controls
• SEC Cries Foul for Failure to Disclose Private Equity Fund Expense Allocation Practices
• Plus Ça Change, Plus C’est La Même Chose: Robo-Advisers and Advertising Issues
• 12b-1 Enforcement Continues

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Many chief compliance officers struggle every year with preparing the annual review and, based on the OCIE’s summary of the most frequently identified exam deficiencies; some are not up to the task.  To help you out, Jaqueline Hummel and Hardin Compliance Consulting LLC suggest the following:

The review should answer these questions:

• Were recommendations from the prior year’s annual review implemented?
• Were the firm’s compliance policies and procedures adequate and followed consistently?
• Are there any operational or compliance risks or weaknesses that need to be addressed?
• Should any changes be made to the firm’s policies and procedures?

Here’s a basic outline for the report:

1. Background
2. Overview of the review process
3. Identify the Principal Risks addressed through Compliance Policies and Procedures
4. Business, Industry and Regulatory Developments
5. Evaluation of the Adequacy and Effectiveness of Compliance Policies and Procedures, and Recommendations

Read her full post here

The SEC’s regulatory actions in 2018 involved few surprises but still managed to challenge investment advisers. In reviewing the SEC’s activity over the past 12 months, Jaqueline Hummel at Hardin Compliance Consulting LLC has identified the top regulatory hot buttons to help firms focus their efforts to update their compliance programs for 2019.

Read her full post here.

January Regulatory Updates from Jaqueline Hummel at Hardin Compliance Consulting LLC.

Topics include:

• SEC Risk Alert – Observations from Investment Adviser Examinations Relating to Electronic Messaging
• SEC Continues to Pound Advisers for Inadequate Disclosures on 12b-1 Fees and Revenue Sharing
• FINRA Releases Its Second Annual Report on Examination Findings
• The SEC Embraces the Holiday Spirit and Shows Compassion Regarding Fee Violations
• BDC Adviser Pays $3.8 Million for Expense Misallocation, Valuation Missteps, and Improper Handling of MNPI

Read the full post here