RCA Symposium Explores Common Examination Risk Areas (Part Two of Two)

An all-star cast of chief compliance officers (CCOs) and regulatory attorneys offered their thoughts on common examination risk areas at the Compliance, Risk & Enforcement Symposium sponsored by the Regulatory Compliance Association (RCA). Moderated by Robert Van Grover, partner at Seward & Kissel, the program featured Lawrence S. Block, managing director, counsel and CCO of Island Capital Group; David L. Fitzgerald, general counsel and CCO at Gabelli & Company; Lucy Frew, partner at Walkers; Michael C. Neus, general counsel of ExodusPoint Capital Management; Heather Traeger, CCO of the Teacher Retirement System of Texas; and Steven A. Yadegari, chief operating officer and general counsel at Cramer Rosenthal McGlynn. This article, the second in a two-part series, discusses challenges associated with fee and expense allocations; social media; and political contributions, as well as the current regulatory climate in the Cayman Islands. The first article covered compliance issues that are likely to come under SEC scrutiny during an examination, including an adviser’s culture of compliance; marketing and other disclosures; addressing past compliance deficiencies; compliance training; and cybersecurity. For additional coverage of events sponsored by the RCA, see “Best Practices for Investment Advisers Using Social Media to Mitigate Advertising Rule Violations and Other Risks” (Mar. 23, 2017); “Risks With Investment Allocation, Trade Execution, Soft Dollars, Client Solicitation and Valuation” (Apr. 14, 2016); and “Issues Pertaining to the Custody Rule, ERISA, Client Agreements, Fees, Codes of Ethics and Confidentiality” (Apr. 7, 2016).

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