Doug Cornelius on compliance for private equity real estate
Under the Investment Advisers Act, investment advisers selecting broker-dealers for executing client trades have an obligation to seek to obtain “best execution” of those transactions. The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a new risk alert highlighting many of the most common deficiencies that the OCIE staff has cited in recent examinations of advisers’ compliance … Read more »
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations announced its 2018 examination priorities. This year, the examination priorities are broken down into five categories: Compliance and risks in critical market infrastructure; Matters of importance to retail investors, including seniors and those saving for retirement; FINRA and MSRB; Cybersecurity; and Anti-money laundering programs. The … Read more »
The SEC’s Office of Compliance Inspections and Examinations published a list of the five compliance topics most frequently identified in deficiency letters that were sent to SEC-registered investment advisers. The five are actually the bulk of advisor compliance requirements. It’s the examples in the five topics that are the most useful indicators. Compliance Rule Compliance … Read more »
IA Watch presented a webinar: Red Hot SEC Exams Topics in 2017, Plus Exam-Prep Steps from Peers Who’ve Survived Recent Exams. The presenters were Fred Shaw, Principal/Director of Compliance, Hamilton Lane Adam Reback, CCO, J. Goldman & Co Chuck Daly, Principal, Constellation Advisers Michelle Martin, CCO, Longfellow Investment Management These are my notes: Even though there … Read more »
Last week the Securities and Exchange Commission issued the 2017 priorities for the Office of Compliance Inspections and Examinations. There are five main items on the list, plus some others. Private funds are still on the list. Retail Investors – Roboadvisers wrap fee programs ETFs – redemption and sales practices Never-before examined Recidivist Multi-branch -(Are … Read more »
The SEC’s Office of Compliance Inspections and Examinations’ 2016 Examination Priorities included a focus on individuals with a history of disciplinary events. That priority has been put into action. The SEC issued a new Risk Alert on upcoming examination. OCIE is undertaking an initiative to examine the supervision practices and compliance programs of registered investment … Read more »
I was chatting with a compliance examiner from the Securities and Exchange Commission and heard that the format for private fund exams had changed. Given the complexity and diversity of business models for private funds, the SEC is trying to narrow the scope of its examination. Presumably to help in that effort, the SEC examiners … Read more »
Securities and Exchange Commission Examiners are beefing up their staff and are more likely than ever to show up on your doorstep. So what are the likely outcomes? The SEC recently announced that it’s shifting resources from the broker-dealer side over to the investment adviser side. It’s leaving the broker dealers for FINRA and putting … Read more »
If you are looking for something to read during the long Thanksgiving Weekend or a great holiday present, pick up a copy of the newly released The US Private Equity Fund Compliance Guide, Volume III. PEI Media just released this follow up that updates the original 2012 edition with the ongoing review and actions of … Read more »
Last week I was able to share with you the introductory letter from a firm that recently registered with the Securities and Exchange Commission and quickly received a meet and greet request. That same reader was nice enough to share his experience with me and the readers of Compliance Building. The SEC had a four … Read more »