Joot Blog

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

CCO Tech Announces First Ever Compliance Automation Solution for Registered Investment Advisers

Oct 1, 2018 10:30:38 AM / by Bo J. Howell posted in Corporate Governance, Investment Advisers, Service Providers, Advisers Act, CCO Tech, Compliance, Compliance Technology, Directors/Trustees, Form ADV, CCO Technology, SEC Filing Manager, Technology

FOR IMMEDIATE RELEASE

Cincinnati, OH (October 1, 2018) - CCO Tech today announces the release of its SEC Filing Manager, the first module of an integrated web-based compliance system for small- and mid-sized registered investment advisers (RIAs). SEC Filing Manager automates the completion of Form ADV, the starting point for regulatory compliance filing for every SEC-registered investment adviser. Additional modules will soon be released to create a comprehensive compliance system.

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The BIG Reveal: Welcome to the Future of Compliance

Aug 24, 2018 10:00:41 AM / by Bo J. Howell posted in Investment Advisers, Advisers Act, CCO Tech, Compliance, Compliance Technology

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Did AI just result in 13 settlements?

Jul 6, 2018 7:30:55 AM / by Bo J. Howell posted in Enforcement, Form PF, Investment Advisers, SEC, Advisers Act, Artificial Intelligence, Compliance, Disclosure, Form ADV

At the beginning of June, the SEC announced settlements against 13 private fund advisers[1] for failing to provide the required information in Form PF.[2] Generally, Form PF requires information on private funds managed by investment advisers if the total assets of the private funds are over $150 million. The form, which became effective in 2012, asks for information on a private fund’s assets under management, strategy, performance, investments, and other areas. The form must be updated annually or when there is a material change to the information in the most recent filing. As stated in its orders, the SEC and other regulatory, such as the Financial Stability Oversight Council, use the information in Form PF to watch systemic risk in the private fund industry. Additionally, the SEC uses the form in regulatory exams and investigations. (Emphasis added.) The same is true for Form ADV.

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IM Director's Recent Remarks on Standards of Conduct & Liquidity Risk Management

May 25, 2018 8:30:21 AM / by Bo J. Howell posted in Investment Advisers, Liquidity, SEC, SEC Rule, SEC Updates, Uncategorized, 1934 Act, Advisers Act, Brokers, Compliance, Directors/Trustees, Disclosure

IM Director's Recent Remarks on Standards of Conduct & Liquidity Risk Management

by Peter Michael Allen

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SEC Decides it's Time to Help Investors Understand the Difference between Brokers and Advisers

Apr 21, 2018 8:31:27 AM / by Bo J. Howell posted in Fiduciary, Investment Advisers, SEC, SEC Rule, SEC Updates, 1934 Act, Advisers Act, Brokers

The SEC has finally proposed a rule that will help clarify the distinction between brokers that refer to themselves as "financial advisors" and investment advisers. (We won't get into why it took so long or how this is a response to the Department of Labor's fiduciary rule, which was recently vacated by federal courts.) Most investors are unaware of the difference and the legal standards that apply to both. In the case of brokers, they are not fiduciaries, which means they do not have to act in the best interest of customers. Investment advisers, however, are fiduciaries and must always act in the best interest of clients. This may seem like a subtle distinction, but it's hugely important for investors that are not well-versed in the working of our securities markets.

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Starting a Compliance Program

Apr 1, 2018 10:14:33 PM / by Bo J. Howell posted in Investment Advisers, SEC Examinations, 1940 Act, Advisers Act, Compliance

In January 2018, The SEC’s Fort Worth regional office held a teleconference that summarized the SEC’s 2017 exam findings and its focus areas for 2018. The staff noted that some of the common weaknesses in compliance programs for investment advisers include:

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