Regulatory Alert: New Form N-PX Reporting Requirements for Investment Advisers Which Are 13F Filers
August 12, 2024
If your investment adviser firm is required to file Form 13F, please be aware that your firm is now required (subject to certain exceptions) by the United States Securities and Exchange Commission (“SEC”) to file an annual report on Form N-PX by August 31, 2024. This report will cover the most recent 12-month period ending June 30 and must include the firm’s proxy voting record related to executive compensation matters.
Regulatory Alert – SEC Amends Reg S-P
May 28, 2024
The U.S. Securities and Exchange Commission (SEC) has adopted amendments to Regulation S-P which require investment adviser firms registered with the SEC to adopt written policies and procedures for incident response programs to address unauthorized access to or use of customer information including procedures for providing timely notification to customers affected by an incident involving sensitive customer information.
2024 SAA Certification Entitlement
April 12, 2024
The FINRA 2024 Entitlement Certification period will begin on Monday, April 15. This is when FINRA begins requiring all Super Account Administrators (“SAA”) to certify the other administrators and users with accounts on the IARD/Web CRD system. The SAA for your investment adviser firm has the ability to create/delete other administrators and user accounts. An administrator can create/delete user accounts. For more information about the importance and responsibilities of the SAA, see the following website: https://www.finra.org/filing-reporting/entitlement/super-account-administrator-saa
Beware of Phishing Emails Impersonating FINRA
On Thursday, April 4, we received numerous inquiries from investment adviser firm owners and/or senior executives who had received an unexpected email supposedly from FINRA’s Chief Legal Officer or Chief Information Officer which utilized an email address ending in @ data-finra .org. In response, our Consulting Team contacted the IARD Entitlement Support Line which confirmed that these emails did not originate from FINRA.
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