On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more
9/11/2024
/ AML/CFT ,
Anti-Money Laundering ,
Asset Management ,
Beneficial Owner ,
Currency Transaction Reports (CTR) ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Patriot Act ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On May 16, 2024, the SEC amended Regulation S-P to impose new data privacy and security requirements on broker-dealers, registered investment advisers, investment companies (whether or not they are registered with the SEC),...more
5/24/2024
/ Breach Notification Rule ,
Broker-Dealer ,
Data Breach ,
Documentation ,
Incident Response Plans ,
Investment Companies ,
ISOs ,
Notice Requirements ,
Policies and Procedures ,
Popular ,
Recordkeeping Requirements ,
Regulation S-P ,
Securities and Exchange Commission (SEC)
Starting May 28, 2024, the settlement cycle for most transactions in U.S. securities will shorten from T+2 to T+1 as a result of rule amendments adopted by the Securities and Exchange Commission (SEC).1 The SEC also adopted a...more
On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more
3/8/2024
/ AML/CFT ,
Closed-End Funds ,
Compliance ,
Customer Due Diligence (CDD) ,
Employee Training ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
FinCEN ,
Internal Controls ,
Mutual Funds ,
Notice of Proposed Rulemaking (NOPR) ,
Patriot Act ,
Policies and Procedures ,
Private Funds ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Reporting Requirements ,
Risk Assessment ,
Travel Rule
Summary of the Recent SEC Actions -
On August 8, 2023, in yet another set of enforcement actions in the space, the U.S. Securities and Exchange Commission (the “SEC”) settled charges against ten broker-dealers and a dually...more
The Securities and Exchange Commission (the “SEC”) has proposed new rule 206(4)-11 (the “Proposed Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”). If adopted, the Proposed Rule would require registered...more
On December 20, 2020, the Securities and Exchange Commission (the “SEC”) adopted reforms under the Investment Advisers Act of 1940, which modernized rules that govern investment adviser advertising and payments to solicitors....more
On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more
10/4/2022
/ Broker-Dealer ,
Compliance ,
Electronic Communications ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Penalties ,
Policies and Procedures ,
Recordkeeping Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934