Compliance Content

The Department of the Treasury published in the Federal Register a request for information on uses, opportunities, and risks of artificial intelligence (AI) in the financial services sector. The RFI uses a broad definition AI, which Treasury views as encompassing "a wide range of...

On May 20, 2024, the National Futures Association (NFA) issued a Notice to Members, Notice I-24-10, declaring the effective date of the recently adopted NFA Compliance Rule 2-52, related Interpretive Notice 9082, and amended Bylaw 301 to be October 15, 2024.

On May 13, the Financial Crimes Enforcement Network and Securities and Exchange Commission proposed new rules (Joint CIP Proposal or proposal) requiring SEC-registered investment advisers and exempt reporting advisers (collectively, investment advisers) to establish Customer...

As part of the SEC's Conference on Emerging Trends in Asset Management, Chair Gensler delivered a keynote address titled, "Jack Bogle, Haystacks, and Putting the Interest of the Clients First." His remarks covered a number of subject areas, including the growth of investment products...

On April 23, 2024, the Department of Labor (DOL) released a final version of its regulatory package on fiduciary investment advice ("Final Package"). The Final Package includes an amendment to the regulation defining who is a "fiduciary" under section 3(21) of ERISA and section 4975(e...

On April 12, the SEC announced that it had charged five investment advisers[1] with violations of Rule 206(4)-1 under the Investment Advisers Act ("Marketing Rule") for "advertis[ing] hypothetical performance to the general public on their websites without adopting and implementing...

On April 17, the staff ("staff") of the SEC's Division of Examinations ("Division") published a risk alert ("Risk Alert") setting forth the staff's observations regarding compliance with the Investment Advisers Act Marketing Rule (Rule 206(4)-1).[1] The Risk Alert states that the...

Last week, the Board of Directors (Board) of the Federal Deposit Insurance Corporation (FDIC) met to discuss proposed resolutions related to the Change in Bank Control Act (CIBC Act). This discussion was prompted in part by an FDIC Director's public statements expressing concern about...

[35678] April 15, 2024 TO: ICI Members AML Compliance Working Group SUBJECTS: Anti-Money Laundering Compliance Intermediary Oversight Investment Advisers Operations Risk Oversight Transfer Agency RE: ICI Files Comment Letter on FinCEN Proposal regarding AML/CFT Program and Reporting...