SEC Risk Alert regarding safety of customer records and cloud vendor diligence. As part of its cybersecurity sweep, the SEC has examined risks related to the storage of customer records and information by investment advisers on cloud-based storage platforms and issued a Risk Alert, “Safeguarding Customer Records and Information in Network…
This is a reminder about the upcoming annual compliance deadlines that may or may not apply to you. Please click HERE to open a summary chart of the filing deadlines. Please feel free to contact us if you have questions or need assistance with any of these filings. Sincerely, Pillsbury IFIM…
In a press release issued by the Securities and Exchange Commission on December 20, 2018, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2019 Examination Priorities. This year’s examination priorities, although not exhaustive, are divided into 6 categories: Compliance and risk at registrants responsible for critical market…
This is a reminder that the 2019 IARD account renewal obligation for investment advisers (including exempt reporting advisers) starts this November. An investment adviser must ensure that its IARD account is adequately funded to cover payment of all applicable registration renewal fees and notice filing fees. Key Dates in the…
The California legislature recently passed a bill that would require public companies whose principal place of business is in California (as indicated in their Form 10-K) to have at least 1 woman on its Board of Directors by the end of 2019. Thereafter, by the end of 2021, these companies…
Covered businesses will need to update policies and procedures for responding to customer inquiries about collection, use, sale and disclosure of customers’ personal information or face stiff enforcement actions. Takeaways The California Consumer Privacy Act of 2018 provides consumers with broad rights to control use of their personal information by…
The rapid growth of cryptocurrency markets, digital asset products and initial coin offerings (ICOs), and the alarmingly high number of fraudulent ICO attempts among them, has prompted the SEC to engage the public in some creative investor education. In its May 16 press release, the SEC announced a mock ICO…
Pillsbury Investment Funds practice co-leader Ildiko Duckor recently spoke with The Hedge Fund Law Report about the strategies and risks inherent in investing in and managing quant funds, which utilize highly sophisticated computer-based models to automate trading activities and are increasingly popular in the “hyper-connected” trading and investment sector. It’s…
The future of the Department of Labor’s Fiduciary rule is in limbo following the Fifth Circuit’s decision striking it down “in toto.” Takeaways The future of the Fiduciary rule is uncertain, particularly in light of the Fifth Circuit’s decision vacating the rule. Retirement plan fiduciaries should continue to stay apprised…
This alert contains a summary of the primary annual and periodic compliance-related obligations that may apply to investment advisers registered with the Securities and Exchange Commission (the “SEC”) or with a particular state (“Investment Advisers”), and commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the Commodity Futures…