Doug Cornelius on compliance for private equity real estate
This year is Anti-Money Laundering year for registered investment advisers. FinCEN promulgated the Investment Adviser Rule. With the Bank Secrecy Act now applicable to registered investment advisers, with a compliance deadline for January 1, 2026, fund managers and advisers will need to update their anti-money laundering policies and procedures to deal with the new regulatory … Read more »
The Securities and Exchange Commission and the Commodity Futures Trading Commission extended the compliance date for the February 8, 2024 amendments to Form PF. The compliance date for these amendments was originally March 12, 2025 and has now been extended to June 12, 2025. For annual filers, that means the new requirements won’t kick in … Read more »
LPL Financial LLC, a dually registered investment adviser and broker-dealer, failed to follow its own anti-money laundering policies and procedures regarding its Customer Identification Program and ongoing customer due diligence obligations. The Securities and Exchange Commission and LPL settled on the charges and the $18 million penalty. What can we learn from the case? On … Read more »
Robinhood experienced massive growth during the pandemic. It had had 5.1 million cumulative net funded accounts by the end of 2019, 12.5 million cumulative net funded accounts by the end of 2020, and 22.7 million cumulative net funded accounts by the end of 2021. Based on the Securities and Exchange Commission’s action against Robinhood, the … Read more »
Deutsche Bank Securities, the registered broker-dealer subsidiary of Deutsche Bank AG, had to pay a$4 million fine for failing to file suspicious activities reports. This year is the year that registered investment advisers need to get fully on the bandwagon with the Bank Secrecy Act. FinCEN promulgated the Investment Adviser Rule to spread the Bank … Read more »
[Edited] On January 23, the US Supreme Court agreed to stay the injunction issued by Eastern District Of Texas that had halted the final implementation of the Corporate Transparency Act. That means the filing deadline for Beneficial Ownership Information reporting is back. Theoretically, that deadline was January 13 and most companies are currently in violation. … Read more »
On Wednesday, the Institutional Limited Partners Association released updates to its ILPA Reporting Template and a new ILPA Performance Template. The goal is to enhance standardization, transparency and comparability in reporting across geographies for private funds. I assume this release is a response to the failure of the Private Fund Rules that the Securities and … Read more »
SpeedRoute is a registered broker-dealer that specializes in routing U.S. equities orders for broker-dealer clients to trading platforms for execution. Being a registered broker-dealer means that SpeedRoute has to comply with the Bank Secrecy Act. Among many other things, that requires SpeedRoute to file Suspicious Activity Reports for suspicious transactions that it knew, suspected, or … Read more »
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This year is the year that registered investment advisers need to get fully on the bandwagon with the Bank Secrecy Act. FinCEN promulgated the Investment Adviser Rule to spread the Bank Secrecy Act requirements. While most investment advisers are doing some form of AML-CFT reviews, the process is now subject to explicit regulatory requirements. The … Read more »