The SEC’s crackdown on firms that sold F-Squared AlphaSector strategies continues to make headlines. Any investment advisor that relies on the use of third-party performance should re-evaluate their internal controls, processes, and procedures to ensure proper controls exist for the creation, review, and distribution of investment performance and related marketing material.
Firms that rely on third-party performance have a number of options related to the policies put in place. ACA Performance Services Partner and Diversified Financial Practice leader, Charlie Stout, and ACA Compliance Group Director, Michelina Cuiccia, will discuss best practices and present case studies and observations on their extensive industry experience.
This discussion will include:
- Recent headlines – SEC’s continued focus on performance;
- Performance reporting policies and controls a firm should put in place to avoid regulatory scrutiny;
- Including case studies and examples of other firm’s approaches;
- Reliance on third-party performance;
- Books and records requirements; and
- Appropriate marketing disclosures.
Throughout the webcast, we will answer questions and respond to comments from attendees.