Category Archives: Uncategorized

On April 28, 2020, the U.S. Small Business Administration published an interim final rule. This interim final rule applies to applications submitted under the Paycheck Protection Program (“PPP”) through June 30, 2020, or until funds made available for this purpose are exhausted. As noted in the interim final rule, the SBA provided a limited safeContinue reading “SBA Extends Safe Harbor for Good Faith Certification to May 14, 2020”

The Securities and Exchange Commission’s Division of Investment Management released new guidance on April 27, 2020, addressing disclosure surrounding an investment adviser’s participation in the Paycheck Protection Program. That guidance is set forth below: Q.  I am a small advisory firm that meets the requirements of the Paycheck Protection Program (PPP) established by the U.S.Continue reading “Updated Guidance for Advisers on Disclosure for the Paycheck Protection Program”

FINRA recently announced that it has postponed all in-person arbitration and mediation proceedings through July 3, 2020. FINRA staff are currently contacting parties to reschedule hearings or offer the option to consider virtual hearing services (via Zoom or teleconference). FINRA reminded parties that postponement would not effect any deadlines, so parties should still be prepared to exchangeContinue reading “The Coronavirus Impact on FINRA Arbitration and Mediation”

On March 27, 2020, the federal government provided relief to certain qualifying businesses in the form of $349 billion in funding authorized under the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”) via the Paycheck Protection Program (“PPP”). The intent and sole purpose for the PPP, is to help certain businesses cover their criticalContinue reading “Participation in the Paycheck Protection Program and Potential Disclosure Obligations?”

Can it benefit you and your business? On Friday March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), that will create an estimated $2 trillion emergency relief package that could significantly impact the U.S. economy and the financial services industry. The CARES Act has allocatedContinue reading “Coronavirus Aid, Relief, and Economic Security Act (the CARES Act)”

I have been receiving an uptick in questions from clients regarding the transition to remote operations and best practices in light of the current pandemic. This is a great question and one that my clients have been really preparing for since Hurricane Sandy. This post is intended to provide an investment adviser’s Chief Compliance OfficerContinue reading “Continued Compliance and Supervision in Light of COVID-19”

Earlier today we received an email from a Chief Compliance Owner and equity owner of an independent investment adviser firm. One of their employees appears to have tragically taken their life. I was deeply saddened by this news. It appears that the causes were the recent performance of the markets and client complaints. It isContinue reading “Help for Those Who Need It”

It has become abundantly clear that the Office of Compliance, Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission is focusing efforts on advisers who advertise and manage investment strategies, portfolios and funds that consider factors or matters that relate to ESG or SRI. In fact, OCIE Director Peter Driscoll said as muchContinue reading “SEC Focusing Efforts on Environmental, Social, and Governance (ESG) and Socially Responsible Investing (SRI)”