SEC Examination Priorities for 2018

Today February 7, 2018, the SEC released its Examination Priorities for 2018. Their focus this year is the retail investor. Prior areas of focus have been subcategorized under the larger retail market. Those include: electronic investment advice, fixed income execution, mutual funds and ETFs, never examined registered investment advisors, wrap accounts and municipal advisors and […]

SEC Continues Enforcement Against PE Funds

The SEC has announced another enforcement action against a PE fund adviser.  Four affiliated fund advisers of Apollo Global Management have agreed to settle an enforcement action for $52.7 million. The charges were misleading fund investors about fees and a loan agreement and failing to supervise a senior partner who charged personal expenses to the funds. […]

I Miss All the Fun

Earlier this week I told investment advisers CCOs not to lose sleep. I suggested that during this 45 day period until registration you should systematically review your compliance and supervisory policies and procedures. I missed the fun yesterday.  Yesterday at the Investment Adviser Association Investment Adviser Compliance Conference Robert Plaze, Deputy Director of the SEC Division of Investment Management warned […]

Don’t Just Wait!

So you got your Form ADV filed with the SEC and you are waiting for March 31. Don’t just wait. As I wrote back in December registration is just the beginning of the journey. Now is the time to find the kinks in your compliance and supervisory programs. Over the next month you should systematically […]