Vigilant Insights Archives

Weathering the Storm: Successful Compliance in A Regulatory Whirlwind

Vigilant Insights Introduction There is little to argue that compliance success has become a more difficult achievement in the past few years. Firms discovered early on that more resources than ever would be […]

Custody Rule Violations | Will Clark Insights

VIGILANT INSIGHTS Introduction A New York Firm was charged $75,000 for allegedly violating custody and compliance rules in relation to their audited financial statements. The […]

SEC Charges for Off-Channel Communications | Donna DiMaria Insights

VIGILANT INSIGHTS Introduction The industry received a big reminder this month that the SEC continues to target off-channel communications by Firms, with Twenty-Six (26) Firms […]

Misleading Statements Lead to $290k Fine | Will Clark Insights

Vigilant Insights Introduction A Private Funds Manager and its Founder were hit with $290k in civil penalty after allegedly misleading its investors. The investors were led to believe that a third […]

Pay-to-Play Violations | Maxwell Baker Insights

Vigilant Insights Introduction A Texas Firm was charged a $95,000 penalty on August 19th for violating the Pay-to-Play Rule. This occurred because an employee had donated over $7,000 to an elected official who’s […]

SEC Sweep for AI Use | Fred Teufel Insights

VIGILANT INSIGHTS Introduction The use of Artificial Intelligence (“AI”) by Registered Investment Advisers (“RIAs”) and Broker Dealers is one of the many targets for SEC […]

Tailored Shareholder Reports Rule | Liam Clarke Insights

VIGILANT INSIGHTS Introduction With the most recent compliance date of July 24th, the Tailored Shareholder Reports Rule is already causing major changes in the way […]

SEC Tailored Shareholder Reports Rule | Liam Clarke Insights

VIGILANT INSIGHTS Introduction The SEC’s Tailored Shareholder Reports Rule had a Compliance Date on July 24th, 2024. As Funds make all the necessary changes to […]

Compliance Implications from Supreme Court Rulings

VIGILANT INSIGHTS Introduction Last month, the Supreme Court overturned the Chevron Doctrine which will likely have a lasting impact on regulatory agencies. As the SEC’s […]

Outsourced Compliance Considerations | Chuck Martin Insights

Vigilant Insights Introduction As Firms continue to commit more time and resources to compliance, many choose to partner with compliance consultants to either fill their […]

Compliance Risks from Political Contributions | Donna DiMaria Insights

VIGILANT INSIGHTS Introduction The Pay-To-Play Rule for Investment Advisors provides on-going compliance difficulties for Firms, especially in an election year. This topic can be complex […]

Firms Struggling with the Marketing Rule | Will Clark Insights

VIGILANT INSIGHTS Introduction As the SEC investigates and charges Firms for Marketing Rule violations, it has been reported that Private Funds and Separately Managed Account […]