3 Compliance Areas You Need To Pay Attention To
Leila Shaver
Owner of My RIA Lawyer, Outsourced CCO and General Counsel to SEC registered firms, Securities Attorney, Compliance Nerd, Speaker, Educator, Lip-sync enthusiast
Recently, the SEC has been fining firms for compliance failures that should be the foundations of the compliance program within your firm. These are your bread and butter compliance tasks and if you’re making mistakes here, it makes the regulators wonder where else you are making mistakes.?
So this week we’ve pooled together some resources we have to help you make sure that you aren’t making these simple mistakes.?
September 2023. SEC Charges 10 Firms with Widespread Recordkeeping Failures
February 2024. Sixteen Firms to Pay More Than $81 Million Combined to Settle Charges for Widespread Recordkeeping Failures
August 2024. Twenty-Six Firms to Pay More Than $390 Million Combined to Settle SEC’s Charges for Widespread Recordkeeping Failures
September 2024. SEC Charges Six Credit Rating Agencies with Significant Recordkeeping Failures. So there is no better place to start our list then by talking about off-channel communication and what you should be doing instead. Watch the video HERE . And just because one part wasn’t enough, you can get even more information about off-channel communications HERE .?
2. Form 13-F. Several firms this year have been caught out by failing to file their Form 13-F in a timely manner. Some firms were luckily spared from considerable fines for self-reporting their failures and completing their filings, however, you can’t always guarantee that self-reporting will save you. That is why we created a blog about Form 13-F to cover all the basics so that you can spend 30 minutes making sure you have your filings in order. Read the blog article HERE .?
3. Proxy Voting. Think you don’t need to read this section because you don’t use proxy voting? I hate to say it, but you still need to be filing Form NP-X to disclose that you don’t engage in proxy voting. Surprised? Here are a few more things that you need to know about compliance and Proxy Voting.?
These are the basics that you need to be making sure you’re getting correct, otherwise, the regulators will definitely come knocking. If this sounds like a lot of work to be doing on your own then why not reach out to our team today to find out how we can help you manage your day to day compliance procedures as well as more complex compliance requirements. You can contact us at +1 770-562-7104.?
Number 1 - 100%. The $739M+ in SEC/CFTC fines in 2024 for off-channel comms makes this a no-brainer. Nothing says 'expensive group chat' quite like a nine-figure penalty ??