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Portfolio Managers Policies and Procedures Investment Adviser

SEC Compliance Consultants, Inc. (SEC³)

How Much Testing is Enough?

Most compliance officers struggle to determine whether they are conducting enough testing to satisfy their obligations under the Advisers Act. In its release adopting Advisers Act Rule 206(4)-7, the SEC stated that an...more

Proskauer Rose LLP

Proskauer's Hedge Start: When Is SEC Registration Necessary?

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An initial question faced by any manager launching a hedge fund is whether or not registration as an investment adviser with the U.S. Secutiries and Exchange Commission (SEC) under the Investment Advisers Act of 1940, as...more

SEC Compliance Consultants, Inc. (SEC³)

Write the Best Annual Compliance Review Ever!

Many chief compliance officers struggle every year with preparing the annual review required under Advisers Act Rule 206(4)-7. To help you out, here’s our guide to writing your annual report....more

Lowenstein Sandler LLP

SEC’s 2024 Examination Priorities for Investment Advisers

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The U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) recently released its annual Examination Priorities for fiscal year 2024 (the Report). The Report underlines the Division’s focus on...more

ArentFox Schiff

2024 Examination Priorities for Investment Advisers from SEC Division of Examinations

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The US Securities and Exchange Commission (SEC) Division of Examinations recently released its 2024 Examinations Priorities, a yearly report that provides insight into the Division’s areas of focus to improve compliance,...more

BCLP

The SEC Declares “You All Fail”

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On November 9, 2021, the SEC released a Risk Alert from the Division of Examinations which provides observations from recent examinations into advisers that offer electronic investment advice...more

Goodwin

U.S. Securities and Exchange Commission Division of Examinations Publishes Observations from its Registered Investment Company...

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The staff of the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (the “Division”) recently published a risk alert spotlighting observations from its “RIC Initiatives” — 200+ examinations of mutual...more

Lowenstein Sandler LLP

SEC Highlights Need For Improvements In Investment Adviser And Private Fund ESG Policies, Procedures, And Practices

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On April 9, 2021, the U.S. Securities and Exchange Commission (the SEC) released results from its recent examinations of particular investment advisers, registered investment companies, and private funds (the firms) that...more

Goodwin

SEC Raises Concerns With Misleading ESG Practices, Highlights Potential Violations

Goodwin on

On April 9, 2021, the U.S. Securities and Exchange Commission (“SEC”) Division of Examinations (the “Division”) issued a Risk Alert regarding the Division’s review of ESG investing. The Risk Alert provides insight into the...more

Dechert LLP

OCIE Publishes Risk Alert on Notable Compliance Issues Found in Investment Adviser Examinations

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The staff of the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (staff) issued a Risk Alert on November 19, 2020 (Risk Alert), related to OCIE’s observations regarding deficiencies in...more

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