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Best of the Blog

At the end of each month, we review all of the alerts for that period from the Our Take regulatory blog and post two “Top 5” lists here, defined by the following criteria: alerts that we feel held the most importance to our audience as a whole, and those that attracted the most readers. Here are the winners so far in 2016, by month.

August 2016

July 2016

Top 5 Regulatory Alerts

  1. OCIE Launches Share Class Initiative (7/14/16)
  2. SEC Charges Fund Manager with Manipulating Inputs to Ensure Inflated Valuations (7/28/16)
  3. Failure to Heed Compliance Consultant’s Recommendations Results in Enforcement Action (7/8/16)
  4. SEC Imposes $300,000 Fine for Wrap Program ADV Missteps (7/18/16)
  5. GC/CCO Fined and Barred for Failing to Disclose Unauthorized Use of Funds (7/12/16)

Most Read Alerts

  1. SEC Charges Fund Manager with Manipulating Inputs to Ensure Inflated Valuations (7/28/16)
  2. GC/CCO Fined and Barred for Failing to Disclose Unauthorized Use of Funds (7/12/16)
  3. Fund-of-Funds Manager Allowed Redemptions Only to Insiders and Favored Clients (7/20/16)
  4. Two RIA Firms Fined/Censured for Failing to Disclose Forgivable Loans from Clearing Brokers (7/19/16)
  5. SEC Imposes $300,000 Fine for Wrap Program ADV Missteps (7/18/16)

June 2016

Top 5 Regulatory Alerts

  1. SEC Proposes Rule Requiring Advisers to Adopt Business Continuity Plans (6/29/16)
  2. Dual-Hatted CCO Barred and Fined (6/1/16)
  3. Large BD/RIA Fined $1 Million for Cybersecurity Breach (6/9/16)
  4. Fund Administrator Charged/Fined for Causing Client’s Securities Fraud (6/20/16)
  5. Private Equity Firm Pays Over $3 Million for Multiple Compliance Violations (6/2/16)

Most Read Alerts

  1. Large BD/RIA Fined $1 Million for Cybersecurity Breach (6/9/16)
  2. The Friday List: The 12-Step Cybersecurity Program (6/17/16)
  3. SEC Proposes Rule Requiring Advisers to Adopt Business Continuity Plans (6/29/16)
  4. SEC Sues RIA for Moving Clients into Proprietary Mutual Funds (6/3/16)
  5. Fund Administrator Charged/Fined for Causing Client’s Securities Fraud (6/20/16)

May 2016

Top 5 Regulatory Alerts

  1. SEC’s Enforcement Director Targets Private Equity (5/18/16)
  2. Massachusetts Sues Large Custody Bank for Over-Pricing Out-of-Pocket Expenses (5/12/16)
  3. DoL Extracts $10 Million Settlement from Investment Manager (5/9/16)
  4. Survey Reports High CCO Turnover (5/2/16)
  5. BD Fined $17 Million and Compliance Officer Fined and Suspended for AML Monitoring Weaknesses (5/19/16)

Most Read Alerts

  1. Large Investment Manager to Pay $1.5 Million for Failing to Supervise Consultant (5/31/16)
  2. SEC’s Enforcement Director Targets Private Equity (5/18/16)
  3. BD Fined $17 Million and Compliance Officer Fined and Suspended for AML Monitoring Weaknesses (5/19/16)
  4. DoL Extracts $10 Million Settlement from Investment Manager (5/9/16)
  5. SEC Chair Expects ETF Regulation (5/23/16)

April 2016

Top 5 Regulatory Alerts

  1. Massachusetts: Robos Do Not Meet Fiduciary Duties (4/13/16)
  2. ETF Authorized Participant Fined $675,000 (4/5/16)
  3. SEC Chair Acknowledges Compliance Outsourcing (4/20/16)
  4. Firm Principals Prosecuted for CCO’s Wrongdoing (4/28/16)
  5. SEC Affirms Industry Bar and Financial Penalties against Chief Compliance Officer (4/4/16)

Most Read Alerts

  1. SEC Chair Acknowledges Compliance Outsourcing (4/20/16)
  2. Firm Principals Prosecuted for CCO’s Wrongdoing (4/28/16)
  3. SEC Affirms Industry Bar and Financial Penalties against Chief Compliance Officer (4/4/16)
  4. SEC Allows Adviser to Purchase Fractional Shares Directly from Client Accounts (4/19/16)
  5. ETF Authorized Participant Fined $675,000 (4/5/16)

March 2016

Top 5 Regulatory Alerts

  1. Chair White Wants More Investment Adviser Examinations and Enforcement (3/23/16)
  2. FINRA Report Targets Robos (3/18/16)
  3. Wrap Sponsors to Pay over $9.5 Million to Settle Share Class and Reverse Churning Charges (3/17/16)
  4. Large Fund Family Receives “Distribution-in-Guise” Wells Notice (3/3/16)
  5. Adviser Ordered to Hire Dedicated CCO (3/8/16)

Most Read Alerts

  1. Firm Failed to Disclose Deteriorating Financial Condition (3/14/16)
  2. Adviser Failed to Disclose Connection to Broker-Dealer (3/21/16)
  3. SEC Staff Requires Ongoing Market Risk Disclosure Reviews (3/11/16)
  4. Chair White Wants More Investment Adviser Examinations and Enforcement (3/23/16)
  5. Wrap Sponsors to Pay over $9.5 Million to Settle Share Class and Reverse Churning Charges (3/17/16

February 2016

Top 5 Regulatory Alerts

  1. SEC Chair Wants Third Party Compliance Reviews of Advisers (2/23/16)
  2. FINRA Conducting Culture Sweep (2/19/16)
  3. Adviser Sanctioned for Failing to Verify Third Party Model’s Performance (2/24/16)
  4. Founder/CEO Resigns over Compliance Failures (2/22/16)
  5. SEC Chair White Says the SEC is Investigating Accredited Investor Due Diligence (2/9/16)

Most Read Alerts

  1. Founder/CEO Resigns over Compliance Failures (2/22/16)
  2. Adviser Sanctioned for Failing to Verify Third Party Model’s Performance (2/24/16)
  3. SEC Chair White Says the SEC is Investigating Accredited Investor Due Diligence (2/9/16)
  4. SEC Chair Wants Third Party Compliance Reviews of Advisers (2/23/16)
  5. FINRA Conducting Culture Sweep (2/19/16)

January 2016

Top 5 Regulatory Alerts

  1. SEC Exam Priorities Letter Focuses on ETFs, Retirement Advice and Private Funds (1/12/16)
  2. FINRA Focuses on Compliance Culture in 2016 Exam Priorities Letter (1/6/16)
  3. SEC Staff Demands Heightened Board Scrutiny of Servicing Fees (1/7/16)
  4. Federal Court Rules that CCO Liable for AML Financial Penalties (1/19/16)
  5. SEC Awards $700,000 Whistleblower Award to Company Outsider (1/26/16)

Most Read Alerts

  1. SEC Orders Adviser to Hire Dedicated CCO (1/15/16)
  2. Federal Court Rules that CCO Liable for AML Financial Penalties (1/19/16)
  3. SEC Exam Priorities Letter Focuses on ETFs, Retirement Advice and Private Funds (1/12/16)
  4. Large Investment Bank Fined $15 Million for Failed Locates and Misleading the SEC Exam Staff (1/27/16)
  5. FINRA Focuses on Compliance Culture in 2016 Exam Priorities Letter (1/6/16)