DISCUSSION OVERVIEW -
- Duty to Establish a Compliance Program
- Chief Compliance Officer (“CCO”)
- Written Policies and Procedures
- Annual Review Process
- SEC Exams and Enforcement
- Code of Ethics
...more
On October 12, 2018, the staff of the Division of Investment Management (“Staff”) of the U.S. Securities and Exchange Commission (“SEC”) issued a no-action letter to the Independent Directors Council (“IDC”) (“IDC Letter”)...more
On June 28, 2016, the Securities and Exchange Commission (the “SEC”) released a proposed rule (the “Proposed Rule”) that would require registered investment advisers (“RIAs”) to adopt written business continuity and...more