US Newsletter | March 2024

US Newsletter

NEWSLETTER: March is always a busy month in the compliance calendar as we wrap up the first quarter of the fiscal year. Filing deadlines always have a habit of creeping up faster than you expect, and it’s all too easy to underestimate the effort required to get your annual Form ADV update over the line. Even if your firm’s filing deadline is June 30th, you’re best placed to start planning now.

After a welcome breather over the last the few months, the SEC has pushed forward with new climate risk disclosure rules, attracting a fair share of controversy. We’re also expecting, cybersecurity rules, updates to the custody rule and oversight requirements for third party service providers in spring alone. As developments rumble on we’ll continue to keep you informed, particularly as preparedness for these new rules should feature heavily in your annual reviews.

The team have also been busy hitting the road, heading to San Diego for Orion Ascent, followed by the ICI Annual Investment Conference at Desert Springs. Amongst the incoming rules and challenges of the day, conversations this year have been far more focused on the positive role technology can play as a powerful enabler for more efficient and effective compliance programs. And while the sector is making no bones about the challenges keeping up with the pace of change, it doesn’t seem like the SEC will be slowing down anytime soon.

Stepping away from some of the major themes, it’s easy to overlook our day-to-day compliance responsibilities. As we think about annual training with many of our clients, I’m reminded of one of our previous articles outlining a best practice approach, ensuring all colleagues understand the ‘what, how and why’. It really does make all the difference.

Finally, don’t forget to pop the end of August in your diary for the first Form NPX filing for Form 13F filers, due at the end of August. Much like a Form ADV, this will take more time than you think so it’s best to start planning now.

Rebecca Thorpe
Chief Executive Officer

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