Vigilant Monthly Newsletter – July 2022
In July, we saw important SEC Releases, SEC Charges, and important insights from Vigilant.
Below is a brief overview of what took place in the month of July, and what is approaching for August.
New Rules, Regulations, and Guidance
Upcoming Filings:
- 8/1/22 – AIFMD Annex IV
- 8/10/22 – Schedule 13G Monthly
- 8/15/22 – AIFMD Annex IV – Fund of Funds
- 8/15/22 – Form 13F Quarterly
- 8/19/22 – Compliance Date for Rule 18f-4 – SEC’s New Derivatives Rule for Registered Funds
- 8/29/22 – Form PF Hedge Fund Quarterly
- 8/29/22 – CPO-PQR
- To stay up to date with the SEC Filing Deadlines in 2022, click HERE to view Vigilant’s Filing calendar.
Events & Public Appearances by Officials:
- 8/4/22 – Closed Meeting
- 8/10/22 – Open Meeting
- To see upcoming 2022 SEC Meetings and Public Appearances click HERE!
Materials:
Vigilant Insights:
5 Common ESG Deficiencies Found From SEC Examinations
- Vigilant has seen 5 common ESG deficiencies found during SEC examinations that can be found by clicking here to learn more!
Industry Pushback Toward SEC’s Proposed Rules on Climate Related Disclosures
- On March 21st, the SEC released proposed rule changes for certain climate-related disclosures to provide investors with consistent, comparable, and decision-useful information for making their investment decisions.
- To view Vigilant’s key takeaways from the industry pushback, click here!
SEC Enforcement/Charges:
SEC Charges Firms for Deficiencies in Customer Identity Theft Prevention
- On July 27th, the SEC charged two large Investment Banks and a Broker-Dealer for deficiencies in their programs to prevent customer identity theft. As a result of these findings the firms paid a cumulative $2.55 Million to the SEC.
- To learn more about the deficiencies that occurred for each Firm, click here!
$200 Million Fine for Misuse of Personal Devices
- On July 14th, a well-known investment bank announced that it expects to pay a $200 million dollar fine because of its unapproved usage of personal devices and the Firm’s record-keeping requirements.
- To view Vigilant’s key takeaway and final conclusion, click here to learn more!
Brokerage Firm Charged by SEC for Violating Reg BI Standards
- On June 16th, the SEC announced that they had charged a registered broker-dealer and five of its registered representatives for violating Reg BI in their recommendation and selling of $13.3 million of unrated, high-risk debt securities, known as L-Bonds, to retirees and other retail investors.
- To learn more about how the issue occurred, what the final findings were, and Vigilant’s final conclusion, click here!
SEC Releases:
4 Key Takeaways from the 2022 PLI Investment Management Program
- On July 26th, 2022, Practising Law Institute (“PLI”) hosted their annual program for 2022 on Current Issues & Trends in Investment Management.
- Vigilant has provided 4 key takeaways regarding insights from the Director of the Division of Investment Management for the SEC that can be found by clicking here!
SEC Opens Request for Comments on Certain Information Providers Acting as Investment Advisers
- On Wednesday, June 15th, the SEC announced that they would open any requests for comments on Certain Information Providers Acting as Investment Advisers.
- Vigilant has provided a brief synopsis of the (1) categories requested for comments, (2) areas of adviser regulation due for a potential increase, (3) the deadline to submit comments, and (4) our final conclusion. Click here to learn more!
The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!
The Team at Vigilant
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