7/6/2009
You'll be busier than ever responding to an announced SEC exam - one more outgrowth of the agency's reaction to the scandals of the last year. And look for a future rule from the SEC designed to improve the agency's surveillance of firms and revise its risk-based matrix that's used to pinpoint which ...
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7/6/2009
If your firm switches from not having to having discretion over client accounts then it also falls under the compliance obligations of the proxy rule.Draw your attention to Advisers Act rule 206(4)-6, known as the proxy voting rule. It requires that firms have written policies and procedures, that ...
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7/6/2009
Expect a proposed SEC rule in the next few days, which you'll be able to comment on, that seeks to bring more transparency to proxy voting. The Commission approved three changes last week that deal with executive compensation, governance disclosure and discretionary voting. The latter proposal may a ...
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