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NEWSLETTER: November was a busy month in the US with Congressional elections taking place on November 8th. Although Republicans took control of the US House of Representatives, it appears that the Senate remains in the hands of the Democrats.
This is important for financial services firms because the aggressive rulemaking approach of the SEC will likely continue unabated unless Congress is united in its oversight. However, the recent collapse of FTX will likely find Republicans and Democrats working together to push through the long-awaited cryptocurrency legislation.
The SEC also held its annual compliance outreach seminar for compliance personnel on November 15th. The seminar gave the SEC the opportunity to discuss its recent rulemaking, including its impact on non-US based investment advisers. This was underscored by recent remarks by the Director of Investment Management, William Birdthistle.
In short, financial firms servicing US clients from outside the US are expected to comply with US regulation as it relates to those clients. At Bovill, we are seeing a current focus by the Division of Examinations on UK firms. These examinations often include inquiries as to the Compliance team’s knowledge of US regulations and a desire to see adequate references to US regulations in firms’ policies and procedures.
We’re currently supporting a number of our clients on their compliance obligations, providing annual reviews, compliance health checks and evaluating registration requirements. We can also take you through our very own mock exam process so do get in touch if you’d like to identify any areas of weakness ahead of an SEC examination.
Rebecca Thorpe
Chief Executive Officer
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