It was the best of times; it was the worst of times. This well-known phrase keeps coming to mind as we evaluate how to move forward when it feels as though the whole world has collectively stopped moving. While approximately 300 million people, just in the United States, have…more
In order to address the question of whether or not you should perform operational due diligence as part of your process to evaluate an investment manager, a broad analysis of the primary underlying risks is helpful. There are two main types of risk that investors need to assess: investment risk…more
Through the course of our work in the investment industry, we discuss fee calculations with both investment managers and investors on a regular basis. We have several clients who have engaged us to perform fee recalculations on their behalf, and we have seen an increase in the number of institutional…more
On June 28, 2016, the Securities and Exchange Commission (SEC) proposed a rule that would require all SEC-registered investment advisers to adopt and implement written business continuity and transition plans to address operational risks related to significant disruptions.
The proposal seeks to address an investment adviser’s fundamental operational…more
In the first quarter of 2015, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) No 2015-02, Consolidation (Topic 810) – Amendments to the Consolidation Analysis. This ASU was issued to respond to concerns surrounding the current generally accepted accounting principles (GAAP) that may require a general partner…more
The landscape of the financial markets is full of constantly evolving regulation, complex financial instruments, customized investment structures, and increased scrutiny from investors. Now may be the time to evaluate your operational due diligence program.
What is Due Diligence?
Generally, due diligence refers to the care a reasonable person would…more
Operational risk involves many qualitative elements such as an investment manager’s controls, design and implementation of systems, and oversight of employees. It is considered an uncompensated business risk because taking on additional risk of this nature is never expected to improve returns. Implementing a strong operational due diligence process…more
The Wealth Manager is a privately-owned firm that provides investment management, manager selection and monitoring, asset allocation, and other financial services.
Broker-dealers operate in a highly regulated environment, which frequently changes. Below are highlights of some key broker-dealer amendments recently adopted by the SEC as well as PCAOB audit findings.
SEC Amendments
The recent Securities and Exchange Commission amendments relate to the net capital rule, the customer protection rule…more
In December 2007, a proposed rule was published concerning the disclosures that must be furnished to plan fiduciaries in order for plan services to be considered “reasonable.” Following a public comment period, public hearing, and interim final rule published in July 2010, the final rule became effective July 1. This…more