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Carl Ayers

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Multiple sources have told affiliate title RCW that the SEC has launched its long-anticipated Division of Examinations sweep tied to the IA marketing rule, and we’ve gotten a copy of what’s described as the sweep exam letter.
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You are advised to ensure that your disclosures around use of testimonials and endorsements are sound, according to a new risk alert from the SEC’s Division of Examinations.
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The SEC will have answers from most advisers by April 1 about their use of the new marketing rule via several new Form ADV questions. Some believe that’s when commission exams to gauge compliance with the new rule will begin in earnest.
'The task force will also analyze disclosure and compliance issues relating to investment advisers’ and funds’ ESG strategies'
It's been a chore to lure accountants in throughout this year of the pandemic.
The GLBA shield offers advisors that fall under the CCPA no protection regarding data breaches, though. Penalties can sting.
The OCIE request raises the specter of a long stretch of working from home.
'If you’re subject to the law, it doesn’t really matter if you’re in or outside of California.'
If 'done incorrectly,' a compliance consultant’s work can inadvertently chart a detailed course for SEC enforcement staff to air a firm’s 'dirty laundry.'
OCIE hopes these observations will spur organizations 'to reflect on their own cybersecurity practices.'

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