DB Fitzpatrick “terminated the chief compliance officer at the time of the Contributions and hired a new chief compliance officer
The three allegedly altered and withheld documents after OCIE examiners commenced an exam in 2016
The order, tied to the coronavirus, also extends to Form PF filings
Strings attached if you wish to delay filing Forms ADV and PF
You may not include disclosure in the relationship summary other than disclosure that is required
The SEC has been reaching out to firms to talk about COVID-19
IAs and B-Ds would have to have “sufficient information to evaluate an Offeree’s financial circumstances and sophistication
Industry comments signal an organized campaign to deluge the SEC and steer the regulator away from going through with proscribed compliance due diligence steps
ESG is hotter than ever, and regulators have noticed the trend
We are proposing to modernize and simplify the Securities Act integration framework for registered and exempt offerings