Ascendent Compliance put together a presentation on Preparation for SEC Examinations. Last year the SEC examined 9% of advisers which represent 25% of the RAUM. Of those exams, 87% had deficiencies, 25% had significant findings, and 14% were referred to enforcement. The SEC has implemented a new telephone assessment for offsite remote exams. The examiners … Read more »
Martin Luther King Jr. Day
It’s the third Monday of January, so that means a day off to celebrate the Birthday of Martin Luther King, Jr. It was officially observed in all 50 states for the first time in 2000. President Ronald Reagan signed a bill creating the federal holiday to honor King in 1983. How to celebrate? Read more »
Weekend Riding – Facing the Cold
That’s me, bundled up for my first bike ride of 2015 on Saturday. I was going to ride first thing in the morning, but shied away when I saw a 9 degree reading on the thermometer. I waited for the balmy afternoon temperature of 22 degrees before enduring a 15 mile ride. Why ride? I’m … Read more »
Compliance Bricks and Mortar for January 16
These are some of the compliance-related stories that recently caught my attention. RBS Loses Senior Compliance Staff, Some Poached by HSBC by Margot Patrick And Rachel Louise Ensign in the Wall Street Journal The departures come as RBS, 80%-owned by the British government, faces a potential multibillion-dollar settlement with the Federal Housing Finance Agency over … Read more »
SEC Exam Priorities for 2015
In 2013 the Office of Compliance Inspections and Examinations at the Securities Exchange Commission laid out their examination priorities for 2013 and did so again last year with its 2014 Examination Priorities. OCIE just released its Examination Priorities for 2015. One item jumps out for a focus for private funds: Fees and Expenses in Private … Read more »
Private Equity Funds and Broker-Dealer Registration
There was a lots of hand-wringing after a speech by David Blass indicated that the SEC was focusing on transaction based fees that private equity funds were earning on securities transactions. Since then, there has been rumblings during presence exams, but no official enforcement action or ruling from the SEC. One group of fees at … Read more »
Cheating In Ethics Class
Is this the worst ethics teacher? 64 Dartmouth Students Charged With Cheating In Ethics Class According to the story, attendance in religion professor Randall Balmer’s “Sports, Ethics and Religion” was measured using handheld devices known as “clickers.” In late October, some students passed their clickers to fellow classmates. Those classmates then used the clickers to … Read more »
Working at Home this Weekend?
I home your home computer works better than this one and that you don;t have to use Fortran, no matter easy it may be to use. Perhaps this is a good example of why past performance is not an indication of future results. I think this gentlemen from 1954 would be very surprised at what … Read more »
Compliance Bricks and Mortar for January 9
These are some of the compliance-related stories that recently caught my attention. Majority of RIAs should move under state regulation: Study by Mark Schoeff Jr. in InvestmentNews Shifting oversight of more registered investment advisers from the Securities and Exchange Commission to states would increase exam coverage at less cost than establishing third-party reviewers, a new … Read more »
Getting Ready for Your SEC Exam – Introductory Presentation
The phone rings and the caller ID pops up with US Securities and Exch… You swallow hard. They are coming. What now? One thing a private fund manager can do to smoothly take the SEC through an exam is to have an introductory presentation when they walk in the door. The SEC examiners will have … Read more »