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April 1 2021 - NRS Insights

Implement Effective Policies and Procedures to comply with the SEC’s Marketing Rule

On December 22, 2020, the U.S. Securities and Exchange Commission (SEC) adopted amendments (the final rule) to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the Advisers Act) to modernize the regulation of investment adviser advertising and solicitation practices.
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February 22 2021 - NRS Insights

New ERISA Prohibited Transaction Exemption (PTE) Effective February 16

The US Department of Labor (DOL) announced that Prohibited Transaction Exemption (PTE) 2020-02, which governs conduct by 3(21) ERISA fiduciaries (generally those who provide non-discretionary advice for a fee), took effect on February 16, 2021. (Under Section 4975 of the Internal Revenue Code, this also applies to persons who provide non-discretionary advice to IRAs.)
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January 4 2021 - NRS Insights

SEC Division of Examinations Will Conduct More Focused Reg BI Examinations Beginning January 2021

Almost six months since Regulation Best Interest’s (“Reg. BI”) compliance date, the Division of Examinations (“Division”) (formerly the “Office of Compliance Inspections and Examinations” or “OCIE”) announced its intent to begin conducting more focused examinations for compliance with Reg. BI in January 2021.
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November 23 2020 - NRS Insights

SEC OCIE Observations: Investment Adviser Compliance Programs

On November 19, 2020 the U.S. Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a risk alert discussing observations on Investment Adviser Compliance Programs. The Risk Alert discusses notable, but not new, compliance issues identified by OCIE dealing with Rule 206(4)-7, the Compliance Rule. What does this mean? OCIE Staff […]
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November 19 2020 - NRS Insights

Observations from SEC OCIE’s Examinations of Investment Advisers

On November 9, 2020 the U.S. Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a risk alert discussing compliance issues and deficiencies observed from its recent exams.
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August 21 2020 - NRS Insights

States Begin to End Grace Periods for IARs Working From Home Due to COVID-19

What just happened? In the early days of the COVID-19 pandemic, many states announced that they would not require individuals working from their homes to register as investment adviser representatives (IARs) as the result of having a “place of business” in the state. On July 31, 2020 the Pennsylvania Department of Banking and Securities sent […]
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July 27 2020 - NRS Insights

SEC Amends Rules Governing Proxy Solicitations

The Securities and Exchange Commission (SEC) voted Wednesday, July 22, 2020 to adopt amendments to its rules governing proxy solicitations, at the same time publishing new guidance meant to help financial advisers apply the amended rules. SEC Chairman Jay Clayton says the final rule amendments, which have been modified from the proposed version published last […]
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July 8 2020 - NRS Insights

Continuing Compliance Challenges from Covid-19

As of this writing (July 1, 2020), it appears that most investment adviser firms have risen to the challenge of keeping their business operating during the first three months of the pandemic. This is a major accomplishment for which you, and all in our industry, deserve tremendous congratulations! That said, most investment advisers are still […]
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June 29 2020 - NRS Insights

OCIE Issues Risk Alert on Private Fund Adviser Exam Deficiencies – Conflicts of Interest

The Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert on June 23, 2020 describing common deficiencies in exams of advisers to private equity and hedge funds (collectively “private fund advisers.”)
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June 9 2020 - NRS Insights

Disclosing your PPP Loan on Form ADV

Many advisers have applied for and received loans under the Paycheck Protection Program (“PPP”) offered by the federal government to help businesses retain employees and stay afloat during the Covid-19 crisis.
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