Mid-Year Regulatory Review – What’s the Latest from the SEC and FINRA?

As we enter the third quarter of 2022 it's clear that both the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) are continuing to demonstrate a steady pace of enforcement.

And there’s no indication that this steady pace will be slowing down. In fact, in recent remarks, SEC Director of the Division of Enforcement Gurbir S. Grewal noted that he’s “been asking staff to look for ways in which to push the pace of investigations since day one.”

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Insider Trading, Digital Assets and MNPI: Regulatory & Compliance Risk

The U.S. Securities and Exchange Commission recently issued a risk alert warning investment advisers of common deficiencies related to their firms' ethics codes and the handling of material non-public information. According to Thomson Reuters Senior Regulatory Intelligence Expert Todd Ehert, the warning is a strong reminder that proper handling and safeguards of material non-public information (MNPI) is a core compliance responsibility for all advisers that should not be overlooked.

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Books and Records in the Regulatory Spotlight

With recent enforcement actions reflecting the Gensler administration’s priority on books and records, can your firm's  audit trail stand up to regulatory scrutiny?

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Minimizing the Risk of CCO Liability

Recent enforcement actions have made it clear that Chief Compliance Officers are at risk of personal exposure if regulatory violations happen under their watch­. The New York City Bar Association recently released a report calling on financial regulators including the SEC and FINRA to adopt a comprehensive and analytical framework for holding CCOs personally liable for violations. 

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Exam Deficiencies for Private Fund Advisers

The SEC Division of Examinations, formerly known as the Office of Compliance Investigations and Examinations (OCIE), provided a discussion of key risks and trends in its 2021 Examination Priorities document.

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