SEC and FINRA case updates from our friends at Hardin Compliance Consulting LLC. Topics include:
SEC Enforcement Report Comes Down Hard on Advisers; Your Chance to Sound Off About the SEC’s Proposed Advertising & Cash Solicitation Rule Changes; Mutual Funds Placed on SEC’s Naughty List
December Regulatory Updates from Cari A. Hopfensperger, and colleagues, at Hardin Compliance Consulting LLC.
Topics include:
- SEC Declares Victory for 2019 Despite all Obstacles: Division of Enforcement Publishes Annual Report for Fiscal Year 2019
- California Has Bigger Fish to Fry with its new Consumer Privacy Act
- New Hampshire to Terminate RIA and BD Firms for Late Renewals
- 2020 CRD/ IARD Renewal Programs
- Speak Now or Forever Hold Your Peace! It’s Your Chance to Comment on the SEC’s Advertising and Cash Solicitation Rule Changes
- Reminder: GIPS 2020
- Form CRS Template
- SEC Extends SIFMA Temporary No-Action Letter Until July 3, 2023
- SEC Dips its Toe into the Water with Blockchain
- Investment Companies Placed on the SEC’s Naughty List
- Small Fund Family Liquidity Risk Management Programs
- NFA Requires Firms to Appoint Swaps Proficiency Requirement Administrator
- Amendments to NFA Promotional Material Rules and Interpretive Notices
What’s Next?: Regulatory Update for November 2019
Regulatory Updates from Cari Hopsfenperger at Hardin Compliance Consulting LLC.
Topics include:
- Between a Rock and a Hard Place: SEC’s FAQs on Conflicts of Interest and Recent Settlements Set Bar Impossibly High for Advisers
- RIAs — Get our Your Checkbooks! It’s Time to Fund Your Annual Renewal Accounts on IARD
- SEC Establishes Asset Management Advisory Committee
- $$ The 2020 Annual Renewal Program is Underway $$
- FINRA Wants to Know if Broker-Dealers are Ready for Regulation Best Interest
- Attention Underwriters, Syndicate Managers and Members, and Selling Group Members
- Does Your Firm Issue Investment Fund Research Reports?
- FINRA 2019 Industry Snapshot
- 2019 Report on FINRA Examination Findings and Observations
- Leaders of CFTC, FinCEN, and SEC Issue Joint Statement on Activities Involving Digital Assets
- SEC Adopts New ETF Rule and Modernizes ETF Regulations
- Notice to Mutual Fund Managers – Review your Performance and Related Disclosures
- NFA Updates Rules on Supervision
SEC’s Relentless Pursuit of Comp-Related Conflict Disclosures: Lessons Learned from SEC and FINRA Cases and Worth Reading for November 2019
Cari Hopfensperger at Hardin Compliance Consulting LLC shares her insights regarding recent SEC and FINRA cases. Topics include:
- SEC Takes Rare Action against Advisers for Voting Proxies
- Large Adviser Fined for Paying Referral Fees without Telling Clients
- SEC Charges Investment Adviser with Custody Rule and Related Violations
- SEC Finds Failures to Supervise Rogue IAR and Implement Sufficient Policies and Procedures
- Inadequate Comp-Related Conflict Disclosures Continue
Filing Deadlines and To-Do List for November 2019
Cari Hopfensperger from Hardin Compliance Consulting LLC shares these important deadlines and to-dos:
- Annual Renewal Program for IARD System
- Form 13F
- Blue Sky Filings (Form D)
- Form PF for Large Hedge Fund Advisers
- Form CTA-PR
- Form CPO-PQR
- FINRA 2020 Renewal Program Preparations
- Rule 17a-5 Monthly and Fifth FOCUS Part II/IIA Filings
- Annual Audit Reports for Fiscal Year-End September 30, 2019
- SIPC-7 Assessment
- SIPC-3 Certification
- SIPC-6 Assessment