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  • September 24, 2017
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    Simons Says

    September 7, 2017

    Let’s let the Department of Labor rest for a few moments and talk about cybersecurity.
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    Simons Says

    August 3, 2017

    On July 12, 2017, at the Economic Club of New York, our new SEC Chairman Jay Clay- ton gave his first public speech and shared his perspective on the Commission, the principles that should guide it, and some of the specific areas where he believes the SEC should take action in the near-term. Identified below are some of his remarks that I consider of significant value to the industry.
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    Who Is In Charge At The SEC?

    May 4, 2017

    From the SEC’s website: “The Securities and Exchange Commission has five Commissioners who are appointed by the President of the United States with the advice and consent of the Senate. Their terms last five years and are staggered so that one Commissioner’s term ends on June 5 of each year. The Chairman and Commissioners may continue to serve approximately 18 months after terms expire if they are not replaced before then. To ensure that the Commission remains non-partisan, no more than three Commissioners may belong to the same political party. The President also designates one of the Commissioners as Chairman, the SEC’s top executive. There are currently three vacancies on the Commission.”
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    April 6, 2017

    On Feb. 7, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert on The Five Most Frequent Compliance Topics Identified in OCIE Examinations of Investment Advisers. These included deficiencies or weaknesses involving violations of rules under the Investment Advisers Act of 1940 (“the IA Act”).


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    March 1, 2017

    No Action Letter On SLOAs & Custody
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    Anything New For SEC Examination Priorities for 2017?

    February 2, 2017

    There are a few surprise changes from the 2016 list of examination priorities. Newly-identified areas of focus include electronic investment advice and National Securities Exchanges. Some old favorites came back into consideration including money market programs, wrap fee programs and FINRA.
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