For nearly a decade now, regulators have placed the Chief Compliance Officer (“CCO”) squarely within the sights of enforcement, on the logic that holding 
CCO’s individually liable for violations would prompt robust compliance programs, and deter lackluster supervision. The reasonableness of such assumptions is a topic for a different post. However, despite these drastically raised
Governance and risk considerations for information security and operational resilience
We continue our discussion of the SEC’s Division of Examinations’ (EXAMS) 2021 Priorities (see here) with an overview of information security and operational resiliency. The daily drumbeat of cyber-intrusion incidents is certain to keep cybersecurity at the top of EXAMS’ focus.
In light of the pandemic forcing a shift to remote work,
Valuation and Fee Assessment – What Your Compliance Program Needs to Have
Over the last three posts to the blog (overview, performance, promoters), we’ve interrupted our previous schedule to provide insight into the U.S. Securities and Exchange Commission’s (“SEC”) recently adopted changes to the rules governing investment adviser marketing and advertising. In today’s post, we resume our previous topic thread focusing on the
Robo Advisors and Custody Rules of the Road
By Marc B. Minor
Investment advisers, rightly, focus much of their attention on satisfying their fiduciary duty through careful investment recommendations. However, advisers’ duties also include ensuring that client cash and securities are transferred for investment, and held, safely by the custodian of those assets.
For robo-advisers, client onboarding, facilitating the transfer of funds and