February 9, 2018

OCIE Releases Its 2018 Examination Priorities

On February 7, 2018, the SEC's Office of Compliance Inspections and Examinations ("OCIE") released its 2018 National Exam Program Examination Priorities. The examination priorities are broken down into five categories: (1) compliance and risks in critical market infrastructure; (2) matters of importance to retail investors, including seniors and those saving for retirement; (3) FINRA and MSRB; (4) cybersecurity; and (5) anti-money laundering programs.

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February 6, 2018

Reminder Regarding Annual Amendment to Form ADV

As a reminder, an SEC-registered investment adviser (an "Adviser") with a December 31st fiscal year-end must submit an annual amendment to its Form ADV on or before March 31, 2018. Since an Adviser will be required to complete the newly amended Form ADV, we recommend preparing the annual amendment as soon as possible. The following is a list of certain new items required by the amended Form ADV.1

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February 5, 2018

SEC sanctions Gemini Fund Services for inflated NAV

Last week, the SEC instituted cease-and-desist proceedings pursuant to Section 203(k) of the Investment Advisers Act against Gemini Fund Services for its calculation of an inflated NAV when it was aware of inconsistencies with the custodian bank’s records.

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