Author: The Securities Compliance Team

Understanding the Enhanced Regulation S-P Requirements

By Thomas Kellerman & The Securities Compliance Team on June 10th, 2024

Posted in Investment Management & Securities

On May 16, 2024, the Securities and Exchange Commission adopted amendments to Regulation S-P, the regulation that governs the treatment of nonpublic personal information about consumers by certain financial institutions. The amendments apply to broker-dealers, investment companies, and registered investment advisers (collectively, “covered institutions”) and are designed to modernize and… Continue reading

Navigating the New Compliance Landscape: Understanding Rule 14Ad-1 and Form N-PX Filing

By Ronald Minsky & The Securities Compliance Team on June 10th, 2024

Posted in Investment Management & Securities

New Rule 14Ad-1 takes effect on July 1, 2024, with filing of Form N-PX due on August 31, 2024, for votes during the July 1, 2023 to June 30, 2024 reporting period. The Rule requires all institutional investment managers that are 13F filers to report say-on-pay votes on the new… Continue reading

Ensuring Compliance: The 2023 DOL Retrospective Review

By Thomas Kellerman & The Securities Compliance Team on June 10th, 2024

Posted in Investment Management & Securities

The Department of Labor (“DOL”) continues to require the completion of a Retrospective Review. The Retrospective Review (the “Review”) requirement of Prohibited Transaction Exemption 2020-02 (the “PTE”) is designed to assist in detecting and preventing violations of, and achieving compliance with, the Impartial Conduct Standards and the policies and procedures… Continue reading

The New Retirement Security Rule: Updated Fiduciary Definition under ERISA

By Thomas Kellerman & The Securities Compliance Team on May 14th, 2024

Posted in Investment Management & Securities

On April 23, 2024, the U.S. Department of Labor (the “DOL”) promulgated a final rule, titled the “Retirement Security Rule” (the “Final Rule”), updating the definition of an “investment advice fiduciary” under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In addition, the DOL issued final amendments… Continue reading

DOL Publishes Final QPAM Exemption Amendment

By Ronald Minsky & The Securities Compliance Team on April 23rd, 2024

Posted in Investment Management & Securities

On April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment to Prohibited Transaction Class Exemption 84-14. The amendment will become effective June 17, 2024. Registered investment advisers that manage accounts that are considered “plan assets” under the Employee Retirement Income Security Act of 1974 (ERISA) and… Continue reading

SEC Adopts Amendments to Modernize Internet Investment Adviser Registration Exemption

By Thomas Kellerman & The Securities Compliance Team on April 16th, 2024

Posted in Investment Management & Securities

Background On March 27, 2024, the Securities and Exchange Commission adopted amendments to modernize the rule for internet investment advisers relying on the exemption that qualifies them for SEC registration as smaller investment advisers. Investment advisers generally need to meet the assets under management threshold, advise a registered investment company,… Continue reading

Five Investment Advisers Charged by SEC for Marketing Rule Violations

By Ronald Minsky & The Securities Compliance Team on April 16th, 2024

Posted in Investment Management & Securities

On April 12, 2024, the Securities and Exchange Commission announced settled charges against five registered investment advisers for violations of the Marketing Rule. The firms have agreed to settle and pay a combined $200,000 in penalties, as well as cease and desist from violating the charged provisions, and to implement… Continue reading

$6.5 MILLION TEXTING PENALTY: Investment Adviser Charged by SEC for Recordkeeping Failures

By Thomas Kellerman & The Securities Compliance Team on April 5th, 2024

Posted in Investment Management & Securities

On April 3, 2024, the Securities and Exchange Commission announced charges against a registered investment adviser for recordkeeping failures regarding personal device communications and pre-clearance of securities transactions in employees’ personal accounts. The firm was charged and agreed to pay a $6.5 million dollar penalty and to implement improvements to… Continue reading

SEC Settles Charges Against Investment Advisers for Misleading AI Claims

By Thomas Kellerman & The Securities Compliance Team on March 21st, 2024

Posted in Investment Management & Securities

Background On March 18, 2024, the Securities and Exchange Commission announced settled charges against two SEC registered investment advisers for making false and misleading statements about their purported use of artificial intelligence (“AI”). The firms agreed to settle the SEC’s charges and pay $400,000 in total civil penalties. Cause of… Continue reading

Multiple locations to better serve your needs—

Hamilton, NJ

100 American Metro Boulevard
Hamilton, NJ 08619
Phone: 609.896.9060
Secondary phone: 800.535.3425
Fax: 609.896.0629
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Marlton, NJ

40 Lake Center, 401 NJ-73, Suite 130
Marlton, NJ 08053
Phone: 856.874.4443
Secondary phone: 888.241.7424
Fax: 856.874.0133
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Yardley, PA

777 Township Line Road, Suite 120
Yardley, PA 19067
Phone: 267.907.9600
Fax: 267.907.9659
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New York, NY

5 Pennsylvania Plaza 23rd Floor
New York, NY 10001
Phone: 800.535.3425
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Philadelphia, PA

The Bellevue 200 S Broad St #600
Philadelphia, PA 19102
Phone: 267.907.9600
Secondary phone: 800.535.3425
Fax: 215.564.6245
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Bridgeton, NJ

78 W Broad St
Bridgeton, NJ 08302
Phone: 856.874.4443
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