Investment Advisers and Sponsors Compliance Policies: Hot Topics
With Form ADV season in the rear view mirror, we recommend that sponsors turn to refreshing their compliance policies to align with rapidly evolving regulatory expectations. To that end, we provide a non-exhaustive list of hot topics to consider below, including with context from SEC examinations and SEC enforcement settlements. Amended Marketing Rule: Sponsors should […]
Posted by Meaghan Kelly, David Blass, and Michael Osnato, Simpson Thacher & Bartlett LLP, on Saturday, May 11, 2024
Editor's Note:
Meaghan Kelly, David Blass, and Michael Osnato are Partners at Simpson Thacher & Bartlett LLP. This post is based on their Simpson Thacher memorandum.
With Form ADV season in the rear view mirror, we recommend that sponsors turn to refreshing their compliance policies to align with rapidly evolving regulatory expectations. To that end, we provide a non-exhaustive list of hot topics to consider below, including with context from SEC examinations and SEC enforcement settlements.
- Amended Marketing Rule: Sponsors should ensure their policies and procedures are updated to reflect the amended Marketing Rule, including as interpreted by the staff’s FAQs. The compliance deadline was November 4, 2022, and both the Division of Examinations and the Division of Enforcement have been testing compliance and aggressively investigating perceived inadequacies. (more…)
