On January 10, 2018, the staff of the U.S. Securities and Exchange Commission’s (“SEC”) Division of Investment Management released answers to 15 questions regarding its October 2016 liquidity risk management program rule. The SEC staff’s guidance, addressed here in part, focused on sub-advisers and In-Kind exchange-traded funds (“ETFs”) (as defined in the rule).
The following article appeared in the December 2017 of NSCP's Currents Newsletter. It was written by ACA's Michael Abbriano.
While the fourth quarter is often the busiest one for regulatory filings and fulfilling other compliance obligations, hedge fund managers should ensure that their compliance programs finish the year on a strong note and that key compliance processes are not neglected.
The following article was featured in the September 2017 edition of Financier Worldwide. It was written by ACA's Jami Jack and Ken Harman.
It is hardly surprising that European technology investment has grown tremendously over the past few years, given the fresh wave of innovative start-ups coming on the scene each month. As a consequence, Europe is now home to a host of mature yet fast-growing technology businesses, such as Auto1, blablacar, Klarna, iZettle and SumUp.
Cyber incidents can have devastating effects on business of all sizes. A breach or malware attack could cripple business operations, lead to financial losses, expose sensitive data, and cause reputational damage.
ACA Compliance Group recently hosted the webcast briefing Regulatory Investment in Trade Surveillance – What You Should Know.
Following the SEC’s recent commentary on Initial Coin Offerings, some investment adviser firm employees will now need to report the personal trades they make in certain types of virtual currency tokens.
The following article, written by ACA's Danielle Joseph and Anne Wallace, appeared in the Hedge Fund Law Report on July 20, 2017.
At the 20th Annual GIPS Standards Conference, back in October 2016, Carl Bacon, chair of the GIPS Executive Committee, and Jonathan Boersma, Executive Director, GIPS, at CFA Institute, provided some insight into the next edition of the GIPS standards, currently being referred to as GIPS 20/20.
The best methodology for calculating and presenting investment performance can be a tricky proposition. The choice will depend on the audience (prospect / current investor) and also what exactly the firm is trying to convey. In fact, we have seen a slight uptick in interest for showing multiple performance streams. Below, we will explore the two most popular methods for calculating and presenting performance and what they mean for both prospective and current clients.
The Guidance Statement on Broadly Distributed Pooled Funds was officially approved on March 13, 2017. The following are highlights of what is included, and what changed from the original drafting.
The Global Investment Performance Standards (“GIPS®”) are a set of voluntary, ethical standards developed by CFA Institute in partnership with other organizations worldwide. The creation of the GIPS standards was spurred by a need for prospective investors to be able to make meaningful comparisons of investment performance across multiple managers, for any given strategy. As acceptance of the GIPS standards continues to spread globally, adoption remains especially strong in the United States. Managers that are registered with the U.S.
Firms that claim compliance with the GIPS standards are required to notify CFA Institute of their claim of compliance. Each firm must submit the GIPS Compliance Form annually, by June 30th. Any data included in this form must be as of the prior December 31st. Firms completing the form currently must include data as of December 31, 2016. Note that the form can be submitted anytime between now and June 30th and is not dependent upon completion of a firm’s 2016 verification.
The 2017 form is now available and includes a few updates.
Proposed revisions to the Guidance on the Use of Supplemental Information were released for public comment on December 1, 2016. The deadline for submitting comments is February 28, 2017. We discuss key points from this draft Guidance Statement below.
The following article written by Brian Lattanzio and Ken Harman was featured in the September 2016 NSCP Currents Newsletter.
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