Tag Archives: CCO

Will Your Investment Adviser’s Use of an Outsourced CCO Survive Regulatory Scrutiny?

January 11, 2022

Although many investment adviser firms desire to outsource the chief compliance officer role to an unaffiliated third-party independent contractor (“Outsourced CCO”), such an arrangement will be scrutinized and could be  challenged by the securities regulator as a violation Rule 206(4)-7 or equivalent rule of the state securities regulator depending upon the facts and circumstances.

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SEC Risk Alert – Investment Adviser Compliance Programs

December 17, 2020

On November 19th 2020, the Office of Compliance Inspections and Examinations (“OCIE”)  of the U.S. Securities and Exchange Commission (“SEC”) released a Risk Alert about its assessment of the compliance practices of SEC-registered investment advisers with regard to SEC Rule 206(4)-7 (the “Compliance Rule”) under the Investment Advisers Act of 1940. In its Risk Alert, the SEC noted that Compliance Rule deficiencies are among the most common discovered by OCIE during SEC registered investment adviser examinations. Click here to read the SEC’s Risk Alert for Investment Adviser Compliance Programs.

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Reviewing an Investment Adviser’s IARD Renewal Statement

November 19, 2020

As a chief compliance officer (“CCO”) reviews his or her investment adviser firm’s Preliminary Renewal Statement from the IARD system, the CCO should consider whether his or her investment adviser firm desires to terminate a firm-level investment adviser state registration or notice filing with a state securities regulator so the firm can receive a regulatory fee refund.

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