Monthly Archives

August 2017

SEC Issues Additional Guidance – Form ADV Updates

By | New in Compliance, SEC

August 17, 2017:  Earlier this week, the Division of Investment Management of the U.S. Securities and Exchange Commission (“SEC”) issued IM Information Update 2017-06, directed to investment advisers filing Form ADV updates.  As widely reported, in August 2016, the Commission adopted amendments to Form ADV with a compliance date of October 1, 2017.[1] As of that date, any adviser filing an initial Form ADV or an amendment to an existing Form ADV will be required to provide responses to the form revisions adopted in the rulemaking. Read More

SEC Risk Alert – Observations from Cybersecurity Examinations OCIE Cybersecurity 2 Initiative

By | New in Compliance, Risk Alert, SEC

August 7, 2017:  The U.S. Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) has released results of its Cybersecurity 2 Initiative. In this Initiative, National Examination Program Staff examined 75 firms, including broker-dealers, investment advisers, and investment companies (“funds”) registered with the SEC to assess industry practices and legal and compliance issues associated with cybersecurity preparedness. The OCIE Cybersecurity 2 Initiative examinations involved more validation and testing of procedures and controls attendant to cybersecurity preparedness than was previously performed in OCIE’s 2014 Cybersecurity 1 Initiative. Read More