Published on Jun 10th, 2022 |

For May’s version of Vigilant’s Monthly Newsletter, we saw an important SEC Proposed Rule, SEC Releases, and important insights from Vigilant.

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

New Rules, Regulations, and Guidance

Upcoming Filings:

  • 6/10/22 – Schedule 13G Monthly
  • To stay up to date with the SEC Filing Deadlines in 2022, click HERE to view Vigilant’s Filing calendar.

Events & Public Appearances by Officials:


Vigilant Insights:

The Marketing Rule One Year Later

  • With the SEC’s New Marketing Rule becoming effective November 4th, 2022, it is important to revisit the Marketing Rule from its initial announcement.
  • Vigilant provided initial and additional takeaways, current industry feedback, additional information about the Rule, and a final conclusion that can be found by clicking here!

2021 SEC Examination Priorities vs. 2022 SEC Examination Priorities

  • With the release of the 2022 SEC Examination Priorities at the end of March 2022, it is valuable to look back and see what focuses have shifted compared to the 2021 SEC Examination Priorities.
  • Vigilant has provided 5 Key Differences when comparing the two Priorities, which can be found by clicking here!

SEC Releases:

SEC Proposes New Rule Towards ESG Investment Practices

  • On May 25th, the SEC released Proposed ESG Related Amendments for Funds and Advisers.
  • Vigilant provided recent negative news in the Industry relating to ESG, a brief synopsis of the proposed Rule, and a final conclusion that can be found here!

EXAMS Issues Reminder for the Marketing Rule 206(4)-1 Compliance Date on November 4th, 2022

  • On May 23rd, the Division of Examinations (“EXAMS”), sent out an email reminder to all SEC RIAs reminding them about the compliance date for the Marketing Rule on Friday, November 4th, 2022.
  • To view what was covered in that reminder from EXAMS, click here!

SEC Fines RIA $760k+ Over Wrap Fees

  • The SEC fined an RIA Firm $760k over Wrap Fees. The RIA and its advisors allegedly benefitted by avoiding paying any transaction fees when recommending share classes.
  • Vigilant has provided a synopsis of the Fine over Wrap Fees that can be found here!

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

The Team at Vigilant

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