Compliance Control: Books and Recordkeeping Requirements
Outline of Advisers Act Rule 204-2 requiring advisers to maintain a comprehensive set of records supporting their investment adviser activities.
June 12, 2023
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Supplemental Comments on SEC Proposal to Shorten Securities Settlement Cycle to T+1
The IAA has submitted supplemental comments on the SEC’s proposal to shorten the securities settlement cycle to T+1. Our supplemental letter requests that the SEC push back the T+1 settlement cycle compliance date to September 3, 2024, replace the proposed requirement of a written agreement with a requirement that investment advisers adopt policies and procedures, and that the SEC take further action to reduce disruption in the foreign exchange (FX) markets.
October 19, 2022
Comments on SEC Proposal to Shorten Securities Settlement Cycle to T+1
We support the SEC’s proposal to shorten the securities settlement cycle to T+1 and provide recommendations that we believe will better balance the SEC’s desire for information with operational realities of how investment advisers engage in securities trading. We also strongly encourage the SEC to not consider moving to a T+0 settlement cycle until the T+1 settlement cycle has been implemented for at least two years and the SEC has had adequate time to analyze data from all stakeholders.
April 11, 2022
2022 Sample Enforcement Letter – New York – Off-Channel Text Messages
This is a sample SEC enforcement letter from 2022 from the New York Regional Office regarding a dual-registrant’s off-channel text messages.
January 26, 2022