Vigilant Compliance Newsletter

Published on Dec 5th, 2024 |

Vigilant Compliance Newsletter - November 2024

Monthly Newsletter

In November, there were important releases that contained both Vigilant Insights and SEC Releases content.

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

Upcoming Filings:

12/05/24 – Form 13G Monthly
12/06/24 – Form N-MFP
12/18/24 – Schedule 13D and 13G Structured Data Requirements
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:

12/05/24 – American Bar Association’s Federal Regulation of Securities Winter Meeting
12/05/24 – Closed Meeting
12/10/24 – Investor Advisory Committee
To see upcoming 2024 SEC Meetings and Public Appearances click HERE!

Vigilant Insights:

Important Compliance Concerns for 2025

In this Vigilant Insights release, we covered important Compliance Concerns heading into 2025 for Firms to be aware of.
To view those important Compliance Concerns, click here.

With a new administration entering the White House in 2025, some are speculating that the regulatory climate the industry has faced for the past four years may lessen in its intensity.
The Marketing Rule, with its obvious role in investor protection, will likely be one example of regulation that continues in the new administration.
Our Director, Will Clark, CIPM, MBA, discussed his thoughts on FundFire regarding what may change in 2025. To view his insights, click here.

The SEC charged a Firm $17,500,000 for misleading statements about the role of ESG in their investment strategies.
Our Director, Maxwell Baker, Esq., provided his thoughts on FundFire regarding what these enforcements could mean moving forward. To view his insights, click here.

The SEC recently released a Risk Alert focusing on frequent deficiencies found during their examinations of Registered Investment Companies (“RICs”).
Bernadette Murphy, MSL, one of Vigilant’s Managing Directors, was recently quoted in an Ignites article discussing the important implications from this alert. To view her insights, click here.

A recent survey that was released in November revealed that although a majority of Financial Service Firms are considering the use of Artificial Intelligence (“AI”), only 12% of the respondents have implemented risk assessments.
Additionally, 92% of respondents have not implemented oversight procedures for vendors related to AI use.
These preliminary results were recently released in an Ignites article and Vigilant Director, Maxwell Baker, Esq., provided commentary on the results of this survey on Ignites. To view his insights, click here.

Vigilant Director, Maxwell Baker, Esq., provided his insights on BoardIQ focusing on disclosures and the use of technology, which was a focus area on the 2025 Examination Priorities.
To view his insights, click here.

SEC Releases:

2024 SEC Enforcement Results

The SEC has released their enforcement results for fiscal year 2024.
To view our comparison of the 2024 SEC Enforcement Results to the 2023 SEC Enforcement Results and our summary of the key Enforcement areas listed in the results, click here.

On, November 7th, the SEC completed their National Compliance Program Outreach Seminar.
There were various topics covered throughout the entire day and we provided key takeaways from the Seminar that can be found by clicking here.

On November 4^th, 2024, the Division of Examinations (EXAMS) released a Risk Alert for Registered Investment Companies (RICs).
To view the factors for selecting Funds they examine, core focus areas during examinations, common staff observations of deficiencies and typical information requested by examiners, click here.

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