Carl Ayers
You may wish to do more before deciding an access person’s personal trades don’t need to be reviewed because they supposedly fall under the code ...
The initiative will dig into investment recommendations, conflicts, compliance and marketing
Last week, we alerted you to a new sweep exam by OCIE that digs into firms’ whistleblower policies (IA Watch, June 18, 2015). IA Watch ...
Morgan Stanley Wealth Management recently added a Culture, Values and Conduct Committee to its Enterprise Risk Management framework to help build a better culture of ...
If your firm skimps on compliance resources and you feel you’re wearing too many hats, you might want to make the powers that be at ...
Responding to deficiencies identified by your regulator with concrete remedies is critical. Actually implementing the pledged solutions on a timely basis is even more important. ...
This SEC document request letter went to an Adviser within the SEC's San Francisco region in 2015. It includes questions about cybersecurity as well as ...
Even Little Red Riding Hood didn’t cry wolf this much. FinCEN’s at it again – moving closer to proposing an AML rule for investment advisers. ...
This is a copy of a 2015 OCIE sweep exam document request letter that focused on whistleblower programs and confidentiality agreements.