Joot Blog

Stay up to date with perspectives, news, and updates pertaining to investment management technology, legal, compliance, and more.

Charles Black

Recent Posts

Reality Check: Observations from Exams in the RIC Initiatives

Nov 9, 2021 1:56:26 PM / by Charles Black posted in SEC, SEC Examinations, Compliance, Disclosure, Policies, Compliance Testing, RIA, Managing Risk

Assess your policies and procedures and improve your RIA and fund compliance programs based on recent SEC observations from exams in the RIC initiatives.

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Social Media Advertising and the New SEC Marketing Rule

Sep 14, 2021 12:53:09 PM / by Charles Black posted in SEC, SEC Rule, SEC Updates, Compliance

Wondering how to align your social media advertising strategy with the new SEC marketing rule? Get our advice here.

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Reality Check: Hypothetical Performance and the New SEC Marketing Rule

Jul 13, 2021 3:29:54 PM / by Charles Black posted in SEC, SEC Rule, SEC Updates, Compliance

Need help understanding what types of hypothetical performance are permitted by the new SEC marketing rule? Read on.

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Reality Check: Best Execution and Selection of Mutual Fund Share Classes for Clients

Sep 24, 2020 1:15:00 PM / by Charles Black posted in SEC, SEC Updates, Compliance

By Charles Black

Reality Check is an occasional blog post series we do where we analyze actual SEC enforcement actions or examination experiences and give you a summary of what to expect in the “real world.”

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Real World Insight From Current SEC and FINRA Exams

Apr 23, 2020 1:15:00 PM / by Charles Black posted in SEC Examinations

A big part of what we do here at Joot is help our clients with their regulatory examinations.  At any given time, we normally have at least a few clients that are undergoing a regulatory exam from either the Securities and Exchange Commission (the “SEC”) or the Financial Industry Regulatory Authority (“FINRA”).  This gives us a certain perspective on the current areas these regulators are focusing on during their exams and what appear to be the latest “hot button” topics. 

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SEC Provides Conditional Relief to Investment Advisers and Investment Companies Impacted By Coronavirus – But Should You Use It?

Mar 18, 2020 12:15:00 PM / by Charles Black posted in Investment Advisers, Investment Managers, SEC Updates, Coronavirus

On March 13, 2020, the SEC announced regulatory relief for investment advisers and investment companies who may be affected by the coronavirus.  The SEC is recognizing that limits on travel, reduced personnel and other business disruptions as a result of the coronavirus may cause delays in meeting regulatory filing deadlines and other regulatory obligations.

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Overhaul Your Privacy Policy, Part 2: Elements of a good privacy policy

Jan 24, 2020 1:00:00 PM / by Charles Black posted in Privacy, Security, Consumer Protection Act

Like most legal documents, privacy policies are fairly bland , and, let’s be honest, few people read them. But the recent enactment of the California Consumer Protection Act (“CCPA”) has Joot fielding privacy policy questions from clients and service providers alike. In our previous post - Is it time to overhaul your privacy policy and notice? - we discussed whether your firm must comply with the CCPA. Today, we spend some more time focusing on the elements of a good privacy policy.

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SEC Exam Priorities 2020

Jan 17, 2020 11:15:00 AM / by Charles Black posted in SEC, SEC Examinations, SEC Updates

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2020 examination priorities on January 7, 2020. OCIE releases this list on an annual basis in order to provide the industry with insights into areas it may focus on thorough the examination process. All the priorities listed on the 2020 list were also on the 2019 list, with some new additions. Which makes us wonder if anything will ever be taken off the list, or if there will just be new additions? Only time will tell.

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