By Charles Lerner, Principal of Fiduciary Compliance Associates and John Roth, CCO of Venor Capital Management

On April 19, 2016, the SEC conducted a Compliance Outreach Program for investment adviser and investment company senior officers.  The conference was broadcast live and will be available on the SEC’s website.

We think the sessions on private funds advisers, questions and answers for advisers with $1 billion or less in regulatory AUM, and hot topics each provided helpful insights into the SEC’s thinking. While the SEC staff and some of the other presenters discussed issues of interest to the SEC, we believe that CCOs would benefit from additional practical advice on how to handle the issues addressed.

 

As a follow up, the MyComplianceOffice webinar on “SEC Hot Button Issues”  [in text link to register here] scheduled for April 27, 2016 will attempt to build upon the SEC’s direction by offering practical advice on how to establish policies and procedures and implement processes to satisfy the SEC’s concerns.

While the SEC staff has often stated that there is no “one size fits all compliance program,” there are certain basics that the SEC expects. During the webinar, we will try to provide investment adviser CCOs and compliance officers with practical guidance.

We hope to help you deal with such questions as:

  • What cybersecurity protections and protocol does the SEC expect investment advisers to have in place?
  • We know the SEC has a strong focus on conflicts of interest, but what are some of the major conflicts and how should investment advisers address them via compliance processes?
  • For advisers to hedge funds and private equity funds, the SEC examination program and enforcement cases have focused on allocation of expenses. How does an adviser ensure it is in compliance with issues raised by the SEC?
  • How are firms dealing with the relatively new Regulation D requirements?

Please join us for a webinar hosted by MyComplianceOffice on April 27 at 12:00 P.M. (EST) and bring your questions!

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