SEC Fines Investment Adviser CCO for Failure to Carry Out Compliance Responsibilities
This case underscores that the SEC will bring enforcement cases against CCOs who have not themselves engaged in misconduct where there is a “wholesale failure” to carry out compliance responsibilities.
July 20, 2022
SEC Staff Bulletin Discusses Account Type and Rollover Recommendations
SEC confirms advisers can use “fiduciary” in Form CRS, but no clear path on how, and issues staff bulletin on how broker-dealers and advisers can satisfy their obligations to act in the best interests of investors when making account-type recommendations.
April 14, 2022
FINRA Publishes Guidance on CCO Liability
FINRA recently published guidance outlining when CCOs’ role is advisory and when CCOs may be liable for failing to discharge their supervisory responsibilities.
March 29, 2022
A Proxy Voting Primer for Uncertain Times
This article discusses requirements for advisers that vote proxies and the status of recent regulatory developments.
March 23, 2022
National Society of Compliance Professionals Releases CCO Liability Framework
The framework looks to clarify the role of CCOs when determining their personal responsibility for a firm’s potential compliance failures
January 18, 2022
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