Compliance Recap: September 2020

In this issue of Vigilant’s Compliance Recap, we have highlighted some important takeaways from the month of September and some reminders for the upcoming months.

New Rules, Regulations, and Guidance

• SEC Adopted Amendments to Modernize Shareholder Proposal Rule
  • Useful for: Shareholders, Investors, Market Participants, Funds, and Fund Advisers
• SEC Adopts Amendments to Enhance Retail Investor Protections and Modernize the Rule Governing Quotations for Over-the-Counter Securities
  • Useful for: Retail Investors, Broker/Dealers 
• SEC Adds Clarity, Efficiency and Transparency to Its Successful Whistleblower Award Program
  • Useful for: All

Events

• FINRA hosting Registration Changes Webinar Series
  • October 8 2-3pm on Enhanced Form U4 and Accessing Continuing Education
• FINRA Compliance Boot Camp Web Events
  • Mini Boot Camps on topics such as Cybersecurity and AML
• SEC to Host October 26 Roundtable on Regulation Best Interest and Form CRS

Upcoming Filings 

• Form 13H Quarterly Filing for Changes- October 9, 2020

  • Form 13H (large trader) quarterly filing is due for the calendar quarter end Q3 2020 for advisers that already have a Form 13H filing obligation and have changes to any of the information reported.
• Form PF for Large Liquidity Fund Advisers- October 15, 2020
  • Large liquidity fund advisers must file Form PF with the SEC on the IARD system within 15 days of each fiscal quarter end.  (This due date assumes a fiscal year end of December 31st and may need to be adjusted according to your firm’s fiscal year end.)
• Form 13F- November 13, 2020
  • 13F quarterly filing is due for Q3 2020 within 45 days after the end of the calendar quarter.

Resources

• In response to the OCIE Risk Alert for “Credential Stuffing” attacks among RIAs and BDs, the experts at Vigilant have created a Risk Mitigation Checklist.
• Top 5 Reasons Vigilant Can provide YOU Value:
  • Check out our LinkedIn post here to learn more!

The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!