• December 12, 2019
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    Advertising Rule and the Cash Solicitation Rule

    December 4, 2019

    The SEC proposed major changes to the Advertising Rule and the Cash Solicitation Rule on Nov. 4. I would recommend at least glancing through the 505-page release, which includes much more detail.


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    November 6, 2019

    Examination Results for FY 2019
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    Simons Says

    September 4, 2019

    On Aug. 21, the SEC released, “Commission Guidance Regarding Proxy Voting Responsibilities of Investment Advisers.” This is the first time, in my memory, that the SEC has provided this much clarification on this issue.
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    August 7, 2019

    There we were, on July 22, talking about disciplinary history policy, and OCIE’s Sept. 12, 2016 Risk Alert, “Examinations of Supervision Practices at Registered Investment Advisers.” Was the SEC spying on us? Has our e-mail been hacked by the government?
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    June 5, 2019

    Peter Driscoll, the Director of OCIE, spoke to attendees at an NRS Conference on April 29 concerning “How We Protect Retail Investors,” highlighting “several areas where OCIE works to protect investors through examinations.”
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    Simons Says

    May 1, 2019

    On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert on Investment Adviser and Broker-Dealer Compliance Issues Related to Regulation S-P – Privacy Notices and Safeguard Policies. These issues were identified in recent examinations of registered investment advisers and provided in the Alert to assist advisers in providing compliant privacy and opt-out notices and adopting and implementing effective policies and procedures for safeguarding client data.
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