Vigilant Insights

2025 Examination Priorities | Maxwell Baker Insights

VIGILANT INSIGHTS Introduction With the 2025 SEC exam priorities released last week, compliance professionals are analyzing their programs to ensure that they meet the regulatory requirements. The use […]

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Cybersecurity Demand Increases for Pension Funds | Laura Arnott Insights

VIGILANT INSIGHTS Introduction Cybersecurity continues to be a focus area for the SEC and the rest of the Financial Services and Investment Management industry. As […]

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Many Firms Abandon Prime Institutional Funds | Fred Teufel Insights

VIGILANT INSIGHTS Introduction As the SEC’s new liquidity and fee requirements went into effect Wednesday, October 2nd, 2024, many Firms have decided to terminate or […]

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$3.4 Million in Fines for Form 13F Failures | Michael Hogan Insights

VIGILANT INSIGHTS Introduction Multiple Firms were fined a combined $3.4 million in penalties for failing to file Form 13F in a timely manner. Form 13F […]

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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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