Vigilant Compliance Newsletter

Published on Jul 7th, 2024 |

Vigilant Compliance Newsletter | June 2024

Monthly Newsletter

In June, we saw Vigilant Insights, SEC Charges and SEC Releases.

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

New Rules, Regulations, and Guidance

Upcoming Filings:

07/08/24 – Form N-MFP
07/10/24 – Form 13G Monthly
07/10/24 – Form 13H Quarterly
07/15/24 – Form PF Liquidity Fund Quarterly
07/29/24 – AIFMD Annex IV
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:

Materials

Vigilant Insights:

Vigilant Director, Donna DiMaria, MBA, discussed the compliance considerations surrounding the Pay-To-Play Rule on WealthManagement.com, and provided some helpful insights for Firms looking to stay compliant.
To view her insights and our conclusion, click here.

Vigilant Director, Will Clark, CIPM, MBA, recently discussed on FundFire how the transitions required by the Marketing Rule may have affected SMA managers differently from Private Funds.
To view his insights and our conclusion, click here.

News and Alerts:

Private Fund Rule Overturned by Appeals Court

The Private Fund Rules adopted in August of 2023, with compliance dates for some Firms this fall, has recently been overturned by a U.S. Court of Appeals.
To learn more about the Final Decision and our conclusion, click here.

SEC Charges:

Cybersecurity Violations Result in $2.1 Million Penalty

A corporation was charged by the SEC on June 18th, 2024, for Cybersecurity Failures relating to control and procedure failures, along with disclosure violations, resulting in a $2.125 million penalty.
To learn more about what was discovered by the SEC and our conclusion, click here.

The SEC recently announced charges against a previous RIA and its Co-Founder for statements made to investors and undisclosed conflicts of interest.
The Firm paid a civil penalty of $350,000 and the Co-Founder paid $250,000 and accepted a 12-month suspension, to settle the charges.
To view what happened and our conclusion, click here.

SEC Releases:

Risk Alert on Broker Dealer Examinations

The SEC released a Risk Alert on June 5^th, 2024, explaining their examination processes on Broker Dealers.
In the Risk Alert, it discussed how they choose Broker Dealers to examine, the risk assessment process, and the documentation that may be requested.
To view our in-depth overview from this Risk Alert and our conclusion, click here.

Recently, SEC Director, Division of Enforcement, Gurbir Grewal, spoke at the Securities Enforcement Forum West about the importance of cooperation with the SEC during examinations.
To view our coverage on his detailed insights and our conclusion, click here.

AI brings with it a host of compliance concerns that specific SEC Commissioners and the SEC Chair discussed to the SEC Investor Advisory Committee.
SEC Chair, Gary Gensler, and Commissioners, Hester Peirce, and Mark Uyeda, provided some insights into how they see regulators fitting into this new technology.
To view their opinions on AI 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!

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