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  • July 27, 2017
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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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    Changing of the Guards

    January 5, 2017

    With 2016 in the rearview mirror, I would like to spend a little time talking about the SEC’s Fiduciary Rule.
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    To Outsource CCOs, or Not?

    November 3, 2016

    While I was reviewing the amended Form ADV that will be required to be used for every filing after October 2017, Part 1, Item 1J. Chief Compliance Officer, caught my eye.
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