Vigilant Insights

SEC Disclosure Amendments (N-PORT and N-CEN) | Liam Clarke Insights

Vigilant Insights Introduction The SEC made changes to certain disclosure requirements recently involving N-PORT and N-CEN filings. The changes were adopted on August 28th, 2024. One of the changes requires […]

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SEC Swing Pricing Proposal Shelved | Fred Teufel Insights

VIGILANT INSIGHTS Introduction The SEC adopted additional requirements on August 28th, 2024, related to Forms N-PORT and N-CEN. Form N-PORTs must be filed monthly instead […]

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SEC Recordkeeping Enforcements | Bernadette Murphy Insights

VIGILANT INSIGHTS Introduction The SEC’s recent charges related to recordkeeping in August clearly indicate that the SEC has no intention of relenting. Twenty-six (26) Firms […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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