On August 25, 2016, the Securities and Exchange Commission (SEC) issued Release No. IA-4509 which adopted amendments that impact Form ADV requirements and various Investment Advisers Act rules. These amendments require additional, enhanced information relating to investment advisers’ separately managed accounts (SMAs), make clarifying and technical changes for other…more
On June 28, 2016, the Securities and Exchange Commission (SEC) proposed a rule that would require all SEC-registered investment advisers to adopt and implement written business continuity and transition plans to address operational risks related to significant disruptions.
The proposal seeks to address an investment adviser’s fundamental operational…more
The deadline for registering your firm’s GIPS compliance is fast approaching.
All firms claiming compliance with the Global Investment Performance Standards (GIPS®) are required to submit a GIPS Compliance Form to the CFA Institute as a notification of compliance. This is an annual filing requirement and firms have until…more
The GIPS Technical Committee is seeking comments on a newly proposed Guidance Statement. The purpose of the Guidance Statement is to address applying the GIPS Standards® to broadly-distributed pooled funds, as the existing standards do not directly address these funds.
Broadly distributed pooled funds (BDPFs) are funds which…more
In December 2015, the Financial Accounting Standards Board (FASB) issued a proposed Accounting Standards Update, Fair Value Measurement (Topic 820): Disclosure Framework—Changes to the Disclosure Requirements for Fair Value Measurement. The proposal is an element of the FASB’s broader disclosure framework project. This project is expected to promote…more
Several years ago, the interim inspection program of auditors of broker-dealers was implemented due to new authority given to the Public Company Accounting Oversight Board (PCAOB) over auditors of SEC-registered broker-dealers by the Dodd Frank Wall Street Reform and Consumer Protection Act.
This summer, the PCAOB released…more
The SEC recently made available the comments received on IA-4091, Amendments to Form ADV and Investment Advisers Act Rules. First, let’s revisit some specifics of the amendments, originally introduced on May 20, 2015. The first of the amendments is to Form ADV Part 1A, specifically as it relates…more
In the first quarter of 2015, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) No 2015-02, Consolidation (Topic 810) – Amendments to the Consolidation Analysis. This ASU was issued to respond to concerns surrounding the current generally accepted accounting principles (GAAP) that may require a general partner…more
Everyone has heard a story about a seemingly great employee who has worked in the business for many years, who would never do anything wrong, and who treats the business like his or her own. And yet, that person is discovered using the company’s checkbook to pay personal expenses…more
The landscape of the financial markets is full of constantly evolving regulation, complex financial instruments, customized investment structures, and increased scrutiny from investors. Now may be the time to evaluate your operational due diligence program.
What is Due Diligence?
Generally, due diligence refers to the care a reasonable person would…more