Published on Dec 1st, 2020 |

It’s December Already! In this issue of Vigilant’s Compliance Recap, we have highlighted some important takeaways from the month of November and some reminders for the end of the year/ NEW year! (2021 we have been waiting for you)

New Rules, Regulations, and Guidance


  • See upcoming SEC Meetings, including the Asset Management Advisory and Investor Advisory Committee Meeting, here.


  • The Role of the CCO
    • On November 19th, OCIE published a Risk Alert regarding the Compliance Rule and how it requires each adviser to designate a CCO to administer its compliance policies and procedures. In the article Vigilant highlighted key practices that are great for CCOs and what the OCIE notices for CCOs. Click HERE to see what those key takeaways are.
  • OCIE’s Examinations of Investment Advisers
    • The Office of Compliance Inspections and Examinations (OCIE) conducted examinations focusing on SEC-registered investment advisers operating from multiple branch offices and with operations geographically dispersed from the adviser’s principal or main office. Want to learn more? Click HERE.
  • OCIE Risk Alert – Investment Adviser Compliance Programs
    • November 19th, 2020, The Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert for Investment Advisor Compliance Programs noting significant compliance issues related to Rule 206(4)-7 (the “Compliance Rule”) under the Investment Advisers Act of 1940. Want to see the Deficiencies and Weaknesses OCIE identified? Click HERE.
  • Herald Investment Marketing hires New President 
    • Herald Investment Marketing, a leading provider of Principal Underwriting and Registered Representative Services for Mutual Funds and ETFs, has named John Brett, a well known industry veteran, as their new President. Interested in learning more about John? Click HERE.
  • Remote Work and the Future
    • Are you aware of the Long Term Implications of continued Remote Work? Click HERE to see Vigilant’s Insights!
  • Survey Results from Vigilant’s Survey (Investment Adviser Compliance)
    • Based off of your results Investment Adviser Compliance was the most important service to our audience. Want to see what we have to offer with Investment Adviser Compliance? Click HERE