Carl Ayers
This is the highway bill signed into law in 2015. It includes a provision eliminating advisers and others from sending out an annual privacy notice ...
Last week, the President signed into law the highway bill. Buried in the new law is a provision amending the Gramm-Leach Bliley Act’s requirement that ...
You won’t need to be part of OCIE’s second cybersecurity sweep exam to be asked about your firm’s approach to IT concerns (IA Watch, Sept. ...
Gemmer Asset Management permits IA Watch to share with you its cybersecurity policy related to access to client information.
A peer shares a copy of the RIA's SEC document request letter from a 2015 exam out of the SEC's New York Regional Office.
A peer shares an example of a form that provides details of a cross trade.
Coming up with a workable industry benchmark for a compliance budget – given the variety of business models and firm sizes – can be harder ...
This one stemmed from an OCIE exam launched in 2015.
Confusion over the custody rule continues to reign more than five years after the SEC revised the rule. And even OCIE examiners don’t always agree ...