Restructuring the compliance function at the Private Fund Compliance Forum 2018

A panelists of fund compliance officers was moderator by a lawyer. The regulatory landscape is changing rapidly, so the compliance function needs to be able to change rapidly. Compliance should have a seat at the table and be embedded in key functions with conflicts and regulatory concerns. Bolted on compliance will be less effective. It’s … Read more »

Proposed Enhanced Investment Adviser Regulation

Yesterday I pointed out the fiduciary duty obligations laid out in the SEC’s new release. The other half of the release is a request for comment on three new proposals to enhance investment adviser regulation. Federal Licensing and Continuing Education Provision of Account Statements Financial Responsibility The SEC notes these as areas where the broker-dealer … Read more »

Most Frequent Advisory Fee and Expense Compliance Issues

Last week, the SEC’s office of Compliance Inspections and Examinations released a risk alert on Most Frequent Advisory Fee and Expense Compliance Issues Identified in Examinations of Investment Advisers. It was a bit shocking. Shocking mostly because the issues are mostly mechanical procedural errors that were contrary to the investment advisory agreement: Using a different … Read more »