laurenbshapiro

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has released its latest National Exam Program Risk Alert - “Share Class Initiative.” The OCIE publishes risk alerts to highlight the risks identified during the course of the examination program. The latest focus of advisory activities relates to conflicted recommendations to clients, fees charged, and disclosure practices. [...]

FinCEN issued interpretive guidance in connection with the customer due diligence (“CDD”) requirements of the CDD Rule. Pursuant to the CDD Rule, published on May 11, 2016, covered financial institutions must now obtain, verify, and record the identities of beneficial owners of legal entity customers. Further, covered financial institutions must now implement and maintain appropriate [...]