ACA Spotlight Blog

GRC Spotlight Blog

Governance, risk, and technology insights from ACA's experienced team

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June 13, 2019

On June 5, 2019, the U.S. Securities and Exchange Commission (“SEC”) passed Regulation Best Interest (“Reg BI”).  BDs will be required to act in the best interest of their retail customers when recommending any securities transaction or investment strategy. As part of Reg BI, BDs and registered investment advisers (“RIAs”) will be required to provide retail investors with a Form CRS Relationship Summary which discloses the nature of the relationship between the entities and their customers.

June 13, 2019

Given the tone of the business plan with regards to financial crime, and a reiteration of its focus on firm governance and culture, it is no surprise that the assessments by the FCSST focussed on 6 areas. If the indications from the documents requested by the FCSST, and the interviews that took place during the onsite portion of the assessment, are anything to go by, it is clear the FCA is following through on its intent to be more intrusive.

June 11, 2019

Although there are political signals that our current administration will provide financial institutions regulatory enforcement relief in comparison to years prior, this is not the case. As evidenced by the consistent penalties enforced over the past several years, AML/BSA regulatory enforcement remains a top priority. Examples include severe civil monetary penalties now being issued to mid-size and small financial institutions, jurisdictions imposing mandatory certification programs for compliance personnel, and compliance violations resulting in civil prosecution and debarment for compliance executives.

ACA Spring Conference 2019 Miami
June 5, 2019

ACA's Spring 2019 Compliance and Performance Conference was held May 8-10 at the Mandarin Oriental in Miami, Florida.

June 4, 2019

Claiming compliance with the Global Investment Performance Standards (GIPS) is gaining significant traction with credit asset managers due to the increased demand from institutional investors.

M&A Due Diligence and Portfolio Oversight: Minimizing Cyber and Privacy Risks During the Deal Lifecycle
May 30, 2019

Is your firm prepared for the SEC's new cyber focus areas for 2019? Find out what your firm needs to know, and what you can do to prepare.

The Secret Ingredient for Effective Vendor Risk Management
May 30, 2019

Vendor risk management can be painful, time-consuming, and expensive. Get the secret ingredient to capture the full range of vendor risks in our latest blog post.

5 Key Challenges When Tuning AML Transaction Monitoring Software
May 29, 2019

More and more, regulators are examining AML and terrorist financing monitoring software solutions to see if they are tuned correctly; and citing financial institutions who fail to meet the regulatory standards. One issue for both regulators and these institutions is the creation of excessive volumes of “false positive” activity alerts, or alerts on activity that after evaluation, is not determined to be suspicious.

OCC's Semiannual Risk Perspective: What Bank Asset Managers Should Know
May 29, 2019

The Office of the Comptroller of the Currency (“OCC”) recently issued its Spring 2019 Semiannual Risk Perspective, a recurring report of key risk areas and emerging threats to the federal banking system that are monitored by the OCC's National Risk Committee. In this blog post, we summarize the risk areas that impact banking asset management groups, and operational risk, strategic risk, and BSA/AML.

SEC’s OCIE Issues Risk Alert on Data Storage Security
May 28, 2019

On May 23, the U.S. Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert regarding the security associated with cloud and network data storage solutions.

2019 Liquidity Risk Management Program Rule Survey Results
May 24, 2019

ACA Compliance Group is pleased to present their newest survey results in the form of a white paper, 2019 Liquidity Risk Management Program Rule Survey Results.

View of buildings in the city
May 22, 2019

The FCA recently published the conclusions of its review of principal firms in the investment management sector. We examine the relevance of the findings and outline how the FCA rated Mirabella in the review.

SEC Conducting Cyber Compliance Examination Sweep of Registered Investment Advisers (RIAs)
May 22, 2019

The U.S. Securities and Exchange Commission (SEC) has commenced a series of cybersecurity examinations on registered investment advisers (RIAs) which targets Form ADV data related to cloud service providers.

FINRA Provides Guidance Regarding Suspicious Activity Monitoring and Reporting Obligations
May 16, 2019

FINRA recently issued Regulation Notice 19-18 (the “Notice”), which provided guidance to member firms regarding their monitoring obligations with respect to suspicious activity pursuant to the Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) requirements.