Vigilant Compliance Newsletter | February 2024
Monthly Newsletter
In February, we saw Vigilant Insights, SEC Releases, and News and Alerts throughout the Industry.
Below is a brief overview of what took place in the month of February, and what is approaching for March.
New Rules, Regulations, and Guidance
Upcoming Filings:
- 03/07/24 – Form N-MFP
- 03/11/24 – Form 13G Monthly
- 03/16/24 – Form N-CEN
- 03/30/24 – Form ADV Annual
- To stay up to date with the SEC Filing Deadlines in 2024, click HERE to view Vigilant’s Filing calendar.
Events & Public Appearances by Officials:
- 03/06/24 – Open Meeting
- 03/07/24 – Investor Advisory Committee
- 03/07/24 – Closed Meeting
- 03/27/24 – SEC-NASAA-Georgia Secretary Of State Joint Investor Roundtable
- To see upcoming 2024 SEC Meetings and Public Appearances click HERE!
Materials
Vigilant Announcements:
Vigilant Named as 2024 Best Compliance Advisory Firm
- In February, we announced that we were named as the 2024 Best Compliance Advisory Firm by With Intelligence for their Fund Intelligence Operations & Services Awards.
- To learn more about the award, click here.
Vigilant Insights:
Importance of a Strong Culture of Compliance | Chelsea Bosiljevac Insights
- Vigilant Director, Chelsea Bosiljevac, Esq., IACCP®, emphasized the importance of having a strong culture of compliance on FundFire as it relates to the recent recordkeeping and off-channel communication fines.
- To view her insights and our conclusion, click here.
SEC Releases:
- The SEC announced that sixteen (16) Firms were penalized $81 Million for widespread and longstanding recordkeeping failures.
- To view what was discovered, the final results of the findings and our conclusion, click here.
- The SEC adopted amendments to Form PF on February 8th, 2024.
- Their goal is to enhance reporting by large hedge fund advisers to assist regulators in identifying trends, monitoring and assessing systemic risk, and lessening the burden on advisers.
- To view the amendments adopted, Commissioner statements and our conclusion, click here.
- SEC Chair, Gary Gensler, recently spoke at a Yale Law School event about Artificial Intelligence (“AI”) and the important role that regulators play.
- To view the key takeaways from his speech and our conclusion, click here.
- A Broker Dealer was charged $2.2 Million on February 16th for failures to comply with Regulation Best Interest (“Reg BI”).
- To view what happened and our conclusion, click here.
- An RIA was recently charged $1.5 Million by the SEC for failing to provide proper disclosures about the launch of one of its new ETFs.
- To view what happened and our conclusion, click here.
FINRA:
- A FINRA Firm was recently disciplined for failures to properly implement WSPs that would adequately review the electronic communications of its registered representatives.
- To learn more about what happened and our conclusion, click here.
The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!