Nov. 3, 2016
Nov. 3, 2016
The SEC’s Recent Revisions to Form ADV and the Recordkeeping Rule: What Investment Advisers Need to Know About Managed Account Disclosure, Umbrella Registration and Outsourced CCOs (Part One of Two)
OCIE Director Marc Wyatt Details Use of Technology and Coordination With Other Agencies to Execute OCIE’s Four-Pillar Mission
Like many governmental agencies, the SEC’s Office of Compliance Inspections and Examinations (OCIE) has an expansive mandate and limited resources, requiring it to allocate those resources in an informed and careful manner. Despite this fact, compliance officers at fund managers and broker-dealers should not underestimate the risk of OCIE scrutinizing their actions. This is especially true as OCIE enhances its technological sophistication, as well as its ability to detect risks within the market and among individual market players, as it pursues the “Four Pillars” of its mission. These themes were conveyed in a keynote speech by Marc Wyatt, OCIE’s Director, on October 17, 2016, at the National Society of Compliance Professionals 2016 National Conference in Washington, D.C. This article analyzes key takeaways from the speech. For coverage of Wyatt’s first speech as acting director of OCIE, see “Acting OCIE Director Discusses the Office’s Focus on Private Equity Managers and Emphasizes the Importance of Disclosure by Advisers” (May 28, 2015). For analysis of a speech by Wyatt’s predecessor, see “OCIE Director Andrew Bowden Identifies the Top Three Deficiencies Found in Hedge Fund Manager Presence Exams and Outlines OCIE’s Examination Priorities” (Oct. 10, 2014).
Read full article …Five Compliance Lessons Private Fund Managers Can Glean From Och-Ziff’s FCPA Settlement
Attorney-Consultant Privilege? Specific Circumstances Where Fund Managers May – and May Not – Be Able to Use Kovel Arrangements (Part Three of Three)
General Insider Trading Policies and Procedures May Be Insufficient for Hedge Fund Managers to Avert SEC Enforcement Action
Current Trends in Operational Due Diligence and Background Checks
DLA Piper Adds Finance Partner to Its Mexico City Office
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