Published on Nov 4th, 2024 |

Vigilant Compliance Newsletter | October 2024

Monthly Newsletter

In October, we saw a good blend of Vigilant Insights and SEC Releases content, as well as a Vigilant Announcement too.

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

New Rules, Regulations, and Guidance

New Rules, Regulations, and Guidance

Upcoming Filings:

  • 11/05/24 – Form 13G Monthly
  • 11/07/24 – Form N-MFP
  • 11/14/24 – Form CTA-PR
  • 11/14/24 – Form 13F Quarterly
  • 11/14/24 – Form 13G Quarterly
  • 11/21/24 – AIFMD Annex IV – Fund of Funds
  • 11/29/24 – Form PF Hedge Fund Quarterly
  • 11/29/24 – Form PF Private Equity Fund Advisers Quarterly
  • 11/29/24 – Form CPO-PQR
  • 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

Materials

Vigilant Insights:

Many Firms Abandon Prime Institutional Funds | Fred Teufel Insights

  • As the SEC’s new liquidity and fee requirements went into effect Wednesday, October 2nd, 2024, many Firms have decided to terminate or merge their existing Prime Institutional Funds into a Government Fund.
  • Vigilant Director, Fred Teufel, CPA, MBA, CGMA, provided his insights into changes Firms have made on Ignites.
  • To view his insights and our conclusion, click here.

Cybersecurity Demand Increases for Pension Funds | Laura Arnott Insights

  • Vigilant Director, Laura Arnott, CFA, CIPM, IACCP, CTPRP, CRISC, provided her insights into the Cybersecurity risks Pension Funds face on Chief Investment Officer Magazine.
  • To view her insights and our conclusion, click here.

SEC Releases:

  • On October 21st, 2024, the Division of Examinations (EXAMS) released their 2025 Examination Priorities.
  • To view key takeaways from their announcement and our conclusionclick here.

Fund Misstatements Lead to $4 Million SEC Charge

  • On October 21st, the SEC announced a $4 Million Charge to a NY RIA for compliance failures and making misstatements.
  • The RIA was marketing an Investment Strategy for three (3) ETFs that incorporated Environmental, Social, and Governance (“ESG”) factors, but that ended up not being the case upon the SEC’s findings.
  • To view what was discovered by the SEC and our conclusionclick here.
  • On October 10th, the SEC announced charges against a Firm and its controlling members for their use of AI in advertising, and other actions by their controlling officer.
  • To learn more about what happenedclick here.

Vigilant Announcements:

Vigilant Becomes Three (3) Time Hedgeweek Award Winners!

  • For the third year in a row, Vigilant was awarded as the Best Regulatory Advisory & Compliance Firm by Hedgeweek for their 2024 US Awards.
  • To learn more about the Award, 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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