Vigilant Compliance Newsletter | January 2024
Monthly Newsletter
In January, we saw multiple Vigilant Insights, SEC Releases, and News and Alerts throughout the Industry.
Below is a brief overview of what took place in the month of January, and what is approaching for February.
New Rules, Regulations, and Guidance
Upcoming Filings:
- 02/05/24 – Schedule 13D Beneficial Ownership Reporting (Accelerated Filing Deadlines)
- 02/07/24 – Form N-MFP
- 02/12/24 – Form 13G Monthly
- 02/14/24 – Form CTA-PR
- 02/14/24 – Form 13F Quarterly
- 02/14/24 – Form 13G Annual
- 02/14/24 – Form 13H Annual
- 02/20/24 – AIFMD Annex IV – Fund of Funds
- 02/29/24 – Form PF Hedge Fund and Private Equity Fund Adviser Quarterly
- 02/29/24 – Form N-PORT
- 02/29/24 – Form CPO-PQR
- 02/29/24 – NFA Annual Exemption Affirmation
- 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:
- 02/01/24 – Closed Meeting
- 02/06/24 – Open Meeting
- 02/08/24 – Closed Meeting
- 02/27/24 – Small Business Capital Formation Advisory Committee Meeting
- To see upcoming 2024 SEC Meetings and Public Appearances click HERE!
Materials
Vigilant Insights:
Vigilant 2024 Compliance Calendar
- As you continue to prepare for the new year, be sure to check out Vigilant’s 2024 Regulatory Filings Calendar, which includes Filing Deadlines for each Quarter in 2024.
- With Vigilant’s recent Award Win as Best Regulatory Advisory & Compliance Firm by Institutional Asset Manager (“IAM”), we dove deeper into why we believe we won the award and what separates us from our competitors.
- To view our Chief Operating Officer, Chuck Marin’s, detailed remarks about the award, trends we have seen, and Vigilant’s future goals, click here.
- There are indications that the SEC is planning on adopting multiple rules in 2024. The majority are planned for the Spring, but this is a dynamic process; some may end up finalized for the fall.
- To view the potential 2024 sec rule adoptions, click here.
- Building an effective Compliance Strategy is crucial, and is something that can be a big lift for some Firms.
- View Vigilant’s 7 effective compliance strategies for 2024 here.
- We highlighted some of the major SEC actions along with key Vigilant insights you may have missed in 2023. View those releases here.
- Vigilant Director, Fred Teufel, CPA, MBA, CGMA, was quoted in a recent article by Chief Investment Officer Magazine that discussed the impact AI can have on Institutional Investors.
- View Fred’s detailed insights here.
- As FY 2024 is already in full stride, looking back at the history of SEC enforcement related to electronic communication recordkeeping should serve as a reminder to compliance officers how great the regulatory burden can become for missing this crucial task. Learn more here.
SEC New Rule:
- On January 24th, the SEC adopted final rules and amendments to enhance disclosures and provide additional investor protections in initial public offerings (IPOs) by special purpose acquisition companies (SPACs) and in subsequent business combination transactions between SPACs and target companies (de-SPAC transactions).
- To view the rule adoptions and our conclusion, click here.
SEC Charge:
- The SEC announced on December 26th that a New York Private Equity RIA was charged for Policies and Procedures failures, specifically related to failing to supervise.
- These failures related to both the misuse of material, nonpublic information (“MNPI”) and the dissemination of misleading communications with current and prospective investors.
- To view what happened and our conclusion, click here.
News and Alerts:
- FINRA suspended a Broker for 18 months due to violations of Regulation Best Interest (“Reg BI”).
- 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!
