After filing Form CRS ahead of the June 30 2020 deadline, many investment advisers breathed a sigh of relief. However, advisers must remain vigilant as the June 30 deadline was the beginning of a new set of compliance efforts which firms must
Observations from Examinations of Investment Advisers Managing Private Funds
On June 23, 2020, the Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert focused on assisting private fund advisers in reviewing and enhancing their compliance programs, as well as providing information to investors regarding potential private fund adviser deficiencies.
LIBOR Transition Preparedness
OCIE issued an examination initiative on June 18, 2020, regarding firms’ readiness to transition away from the London Interbank Offered Rate (LIBOR). LIBOR, widely used in the United States and elsewhere as a benchmark rate for various commercial and financial contracts, including
SEC Enforcement Action against Morgan Stanley Smith Barney for Providing Misleading Information to Retail Clients
On May 12, 2020, the SEC announced Morgan Stanley Smith Barney (MSSB) agreed to a $5 million penalty to settle charges that the firm provided misleading information to clients in its retail wrap fee programs regarding trade execution services and transaction costs.
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