By Nick Horvath

Vendor due diligence, an oldie… but a goodie.  Vendor due diligence has been a risk mitigation technique since the words Caveat Emptor were first spoken.  But what about today? How much emphasis should your firm place on vendor due diligence? Why should you care? Let us count the ways.

Ever since I founded CCO Tech, we’ve been talking about our proprietary technology and how deeply committed we are to helping you remain independent, protect your reputation, keep your house in order, and achieve peace of mind that your compliance program is buttoned up and exam ready. But we heard from so many of you over the past few months that technology is only part of the solution. Often, you also need a reliable partner, maybe even a compliance steward. Our clients and beta testers have provided great feedback on our system, but they’ve asked for more.

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.

In May, we discussed eight things that you needed to know about the liquidity rule in this article. At that time, we noted that part of the rule was due to take effect in December 2018 for large fund families or June 2019 for smaller fund families. The parts that were delayed until 2019 included the liquidity classifications (i.e., the buckets) and the highly liquid minimum requirement.  More importantly, our third point was that the SEC would have more changes to the liquidity rule in 2018.

1. Its name.

Most people simply refer to the rule as the “liquidity rule”, but its technical name is Rule 22e-4: Investment Company Liquidity Risk Management Programs. If the rule survives in any meaningful form, we should start a contest on whether the industry keeps calling it the liquidity rule or refers to it as Rule 22e-4. Think of Rule 38a-1 under the Investment Company Act. Some people may refer to it as the “compliance rule”, but most simply call it Rule 38a-1.

In Part 1 of our discussion of the use of artificial intelligence in the investment management industry, we discussed how the SEC is getting big data as its first step to developing AI systems. In this second post of our three-part series, we discuss how AI systems are being used by service providers and the impact of those systems on asset managers. Our next post will discuss how asset managers are using and benefiting from AI systems.