Published on Dec 2nd, 2021 |

Vigilant Newsletter | November 2021

November brought some important Risk Alerts and important insights from Vigilant on “Preparing for 2022”.

Also, there are important upcoming filings and events for the month of December.

Below is a brief overview of what took place in the month of November, and what is approaching.


New Rules, Regulations, and Guidance

Upcoming Filings:

  • 12/15/21-TIC Form S due.
  • 12/23/21-TIC Form SLT due.
  • 12/30/21-Periodic Report for CPOs.
  • To stay up to date with the SEC Filing Deadlines in 2021, click HERE to view Vigilant’s Filing calendar.



Vigilant Insights:

Preparing for 2022

  • Prioritizing a plan for your 2022 compliance budget is crucial for staying ahead of Rule changes and other unique challenges.
  • Vigilant has prepared 5 key tips when preparing for your 2022 Compliance Budget and insights on how we can help, which can be found here!

SEC Releases:
Division of Examinations Observes Investment Advisers’ Fee Calculations

  • On Wednesday, November 10th, the Division of Examinations (the “Division”) released a Risk Alert concluding that the Division Staff completed a national initiative that focused on advisory fees, fee disclosures, accuracy of fee calculations, and, more specifically, those charged to retail clients.
  • To view the staff observations and brief synopsis from Vigilant click here!

Division of Examinations Risk Alert for Advisers Providing Electronic Investment Advice

  • On Tuesday, November 9th, the Division of Examinations (the “Division”) released a Risk Alert with the goal of raising awareness of certain compliance issues relating to advisers providing or claiming to provide Robo-Advisory Services.
    • It is important to note that this also includes advisers that recommend, operate, and sponsor discretionary investment advisory programs.
  • Not enough time to read the full Risk Alert? Vigilant created a synopsis here for you!

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