Compliance Programs and CCOs

An IM Insight Special Report: The New Code of Ethics Rule (Part 1 of...

On July 2, the SEC released the final text of new Advisers Act Rule 204A-1, which for the first time requires all SEC-registered advisers to “establish, maintain and enforce” a written personal trading code of ethics. This article is the first in a three-part series on the new rule. While the first two parts will […]

Some Advisers Exiting Fund Business Due to Compliance Costs

Several advisory firms are looking to merge their proprietary funds out of existence by October 5, rather than face the costs of developing a compliance program encompassing the federal securities laws. One source told IM Insight about an adviser “that was specifically looking to get rid of their mutual fund business before October 5.” The […]

OCIE Director Sheds Light on Compliance Program Issues

Last week, OCIE director Lori Richards discussed several issues under the new compliance program rule, in a speech delivered at an Investment Company Institute conference by OCIE general counsel John Walsh. While her (his?) remarks were geared to fund companies, non-fund advisers may find them informative, as well. The highlights: OCIE Will View the CCO as […]

Looking for a Job?

IM Insight hears that headhunters are calling around looking for a CCO for a nice little shop called Bank of America. The salary being offered? A cool $500 – 900K.

Have You Heard?

Many fund groups are planning to hold a special board meeting in September for their boards to approve the compliance policies and procedures of the fund and their service providers. It appears that most funds will not be ready by July said Drinker Biddle partner Diana McCarthy, referring to the traditional July meeting held by […]

Have You Heard?

Some SEC examiners are asking advisory firm compliance officers to write a summary of all of their material compliance breaches that have occurred since their last exam. In some cases, compliance officers are being asked to certify that they havent left anything out. The good news is that the scope of OCIEs e-mail requests seem […]

IM Insight Talks to . . . David D. Brown, IV, Chief of...

Youve probably heard a thing or two about his boss. But as lawyers caught up in the fund scandal can attest, David Brown, a former in-house counsel at Goldman Sachs, has been the day-to-day force behind Eliot Spitzers fund investigations. In an exclusive interview, IM Insight talked to David about the role of compliance officers, […]

Audio Interviews

How to Read an SEC Enforcement Action

Stern Tannenbaum law firm partner Aegis Frumento on how to get the most from reading an SEC administrative order or court complaint.

Most Important Supreme Court Decisions for Advisers and Funds

Find out the high court decisions from recent years that are likely to affect how advisers and investment companies work from Debevoise partner Robert Kaplan. 

Top 10 Cybersecurity Steps to Take Now

Sutherland law firm partner Brian Rubin shares the most urgent cybersecurity steps for investment advisers.

Top Marketing Problems … and Solutions

Get solutions for the top marketing challenges that advisers face from ACA Compliance Group managing director Kimberly Daly

Watch Out for 5 Cybersecurity Myths

ACA Aponix Director Pascal Busnel on the most common cybersecurity myths that may cause firms to spend resources where they may not be needed.

The Hidden Costs of Non-Compliance

Proskauer law firm partner and former SEC Division of Investment Management deputy director Robert Plaze on why the costs of non-compliance go way beyond an SEC penalty.

CCO Liability: How to Protect Yourself

Find out from Blue Edge Capital CCO Margaret Fretz what chief compliance officers may be liable for and best practices to make sure you are protected.

Ethics or Compliance: Making the Choice

Find out the difference an ethics, rather than a compliance, perspective makes at an advisory firm from former Ethics and Compliance Officer Association COO Timothy Mazur.