Tag: SEC3 Communique Total 49 results found.

In February 2015, the SEC’s Division of Investment Management issued guidance to the public with respect to the conflict of interest that arises when individuals and firms doing business, or hoping to do business, with a fund or investment adviser provide gifts, entertainment, favors or other forms of consideration to employees of the fund or adviser.

Wednesday, 25 March 2015

As the SEC has been doing at the start of each year in recent years, the SEC announced its examination priorities for the new year. For 2015, the SEC’s priorities focus on three general areas: (i) protecting retail investors and investors saving for retirement; (ii) assessing market-wide risks; and (iii) using enhanced data analytics to identify illegal activity.

The SEC highlighted certain additional priorities, and of these we think the following are more noteworthy to our investment adviser and registered investment company clients:

Wednesday, 14 January 2015

The SEC’s Divisions of Investment Management and Corporation Finance recently provided guidance (the “Guidance”) to investment advisers regarding their obligations in voting client proxies and retaining proxy advisory firms. The Guidance also covered proxy advisory firms directly regarding their reliance on popular exemptions from the federal proxy rules. In doing so, the regulators addressed the interplay between advisers’ fiduciary obligations and the Proxy Voting Rule. They also clarified that proxy advisory firms, when creating voting guidelines for advisers and institutional investors and acting to apply those guidelines in voting proxies, might jeopardize their ability to rely on exemptions from federal proxy rules.

Tuesday, 22 July 2014

SEC Chair Mary Jo White recently shared steps directors can take to meet various SEC expectations. At the annual Stanford Directors’ College, Chair White highlighted the important role directors play in the eyes of the SEC and set out her planned agenda to discuss:

Tuesday, 08 July 2014

One of the main goals of any registered firm is to avoid an enforcement action.  The more you know about trends with regard to enforcement cases, the better equipped you are to succeed in that endeavor.  The good news is that the SEC is being more transparent with the industry than ever before with regard to goals, focus areas and its approach to enforcement.

Thursday, 22 May 2014

As if April 15th wasn't bad enough? In addition to it being Tax Day, the U. S. Securities Exchange Commission's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") issued a Risk Alert discussing the planned sweep exams that will assess registrant cyber-security readiness and to gather information related to recent experiences with cyber threats.

Friday, 18 April 2014

The Securities and Exchange Commission announced on Thursday, February 20th that its Office of Compliance Inspections and Examinations (OCIE) is launching an initiative directed at investment advisers that have never been examined, focusing on those that have been registered with the SEC for three or more years.

Monday, 24 February 2014

The Volcker rule was adopted on Tuesday, December 10, 2013 by five regulatory agencies including the Securities and Exchange Commission (the “SEC”). The original proposal was drafted in 2010 and received more that 19,000 comment letters from industry participants. The final rule was adopted by the SEC with a narrow 3 to 2 vote. It is interesting to read the strong dissenting opinions by Commissioners Gallagher and Piwowar who thought that the rule was so substantially different than the proposal that it should have been re-submitted for comment and not presented to the SEC for adoption in the rushed manner that it was presented at year-end. Commissioner Gallagher mentioned that the SEC received the final draft on December 5 which left little time for careful consideration.

Thursday, 12 December 2013

Stephen L. Cohen, the Securities and Exchange Commission’s (“SEC”) Associate Director of Enforcement, spoke recently at the Society of Corporate Compliance and Ethics’ Annual Conference.  In his remarks he noted what he considers characteristics of effective and ineffective compliance programs and how having a strong compliance program can impact the SEC staff’s decision on whether or not to bring an enforcement case against a firm as well as the extent of penalties and sanctions pursued. Mr. Cohen said: “When evaluating a company’s misconduct, we typically give credit when a company can demonstrate a strong compliance culture”.

Tuesday, 03 December 2013

As a result of the rescission of Rule 4.13(a)(4) for commodity pool operators (CPOs) advising funds offered to qualified eligible persons and the narrowing of the exclusion under Rule 4.5 available to registered investment companies, almost 600 new CPOs registered with the Commodity Futures Trading Commission (CFTC) and became members of the National Futures Association (NFA). The number of registered CPOs increased from 1,200 to 1,800. Currently-registered CPOs manage over 6,000 commodity pools. Before the advent of the new registrants, the first audit was generally expected within the first year of registration.

Wednesday, 13 November 2013

On September 23, 2013, SEC regulations adopted on July 10, 2013 to implement Section 201(a) of the JOBS Act will be effective. We are not seeing firms rush to generally solicit by marketing heavily or un-password protect their websites. In fact, what we are seeing is firms proceeding thoughtfully and cautiously. Most realize at this point that what initially was perceived as a new found freedom for private funds, is actually a maze of hurdles that must be carefully cleared before private funds can actually determine that they should in fact take advantage of new Rule 506(c) and “generally solicit”.

Tuesday, 29 October 2013

On the infamous day in July when the SEC loosened the reins on general solicitation and proposed related new rules and rule amendments, the SEC also finalized the "bad actor" disqualification rules for most private placements (as required by the 2010 Dodd-Frank Act).

Monday, 05 August 2013

On July 19th, the SEC announced the establishment of supervisory cooperation arrangements (memoranda of understanding) with European regulators related to the asset management industry. While the SEC initiative deals only with European regulators, it may signal increased interest by the SEC in its asset management registrants outside the United States especially given that some are new to their jurisdiction post Dodd-Frank.

Thursday, 25 July 2013

The Securities and Exchange Commission (“SEC”) voted yesterday to eliminate the ban on general solicitation and advertising for offerings conducted under Rule 506 of Regulation D. Private investment funds can now offer their securities freely and solicit investors with no restriction provided that they:

take reasonable steps to verify that the investors are accredited investors; and

all purchasers of their securities fall within one of the categories of persons who are accredited investors under an existing rule (Rule 501 of Regulation D) or the fund reasonably believes that the investors fall within one of the categories at the time of the sale of the securities.

This means that although offers of fund interests will be unrestricted by private funds that will engage in general solicitation, sales of those interests will be restricted to accredited investors only and will be subject to the new verification requirement regarding accreditation.

Thursday, 11 July 2013

Quarterly Form NFA-PQR for registered CPOs

The first Form NFA-PQR for newly-registered CPOs whose registration became effective on January 1, 2013 is due sixty days from calendar-quarter end, i.e. by May 31, 2013 for the quarter ended March 31, 2013. Form NFA-PQR is filed every quarter by all registered CPOs. The NFA Form PRQ is distinct from the CFTC Form CPO-PQR which must be filed on a quarterly or annual basis depending on the assets under management (“AUM”) of the firm.

Monday, 29 April 2013

We have heard so much about the SEC's focus on private fund managers, but now attention is turning to include registered funds as well. OCIE Deputy Director Drew Bowden has warned the industry to expect upcoming sweeps. Areas of anticipated focus include 12b-1 fees and alternative investment companies.

Friday, 15 March 2013

On February 21, 2013, the SEC announced its 2013 exam priorities. The SEC outlined its market-wide priorities followed by priorities in four distinct examination programs:

Investment Advisers and Investment Companies Broker-Dealers Clearing and Transfer Agents Market Oversight

In each of the above programs, the SEC will examine (a) ongoing risks (b) new and emerging risks and (c) policy issues.

Tuesday, 26 February 2013

Many Commodity Pool Operators (CPOs) are currently in the process of preparing to file the new Form CPO-PQR, which is required by the Commodity Futures Trading Commission (CFTC). Form CPO-PQR is filed with the National Futures Association (NFA). The frequency and extent of reporting on Form CPO-PQR depends on the assets under management (AUM) of a CPO.

Thursday, 14 February 2013

All commodity pool operators (“CPOs”) and commodity trading advisers (“CTAs”) that claimed an exemption last year must re-affirm their exemptions within 60 days from calendar year-end. Firms that claimed exemptions from CPO registration under CFTC Rule 4.5 or CTFC Rule 4.13(a)(3) (the “deminimis exemption”), or Rules 4.13(a)(1), 4.13(a)(2), 4.13(a)(5) as well as firms that claimed an exemption from CTA registration pursuant to CFTC Rule 4.14(a)(8) must re-affirm those exemptions by March 1, 2013 or those exemptions will be automatically withdrawn.

The NFA’s guidance can be found here .

Tuesday, 05 February 2013

In a speech before the Private Equity International Conference yesterday, Bruce Karpati, the chief of the Asset Management Unit of the SEC Enforcement Division reiterated the focus of the Division on private equity and other fund managers. This speech is a sequel to the one delivered by Mr. Karpati last month before the Regulatory Compliance Association which we discussed in our previous communiqué. After reiterating the Division’s increased attention on fund managers and the fact that Enforcement Staff is participating in exams along with OCIE, Mr. Karpati explained the unique characteristics of private equity funds that make them more susceptible to fraud.

Friday, 25 January 2013

Securities and Exchange Commission (“SEC”) staff has suggested greater involvement and concern by Division of Enforcement staff with respect to examinations of registered investment advisers, including private fund and private equity managers. In a speech before the Regulatory Compliance Association on December 18, 2012, Bruce Karpati, Chief of the Enforcement Division’s Asset Management Unit, indicated that the SEC has established areas within the Division of Enforcement to “work with staff outside the Units on investigations and exams.”

Tuesday, 15 January 2013

There were a number of important regulatory developments in November, which we will cover in detail over the coming weeks. Here are the top three you need to know about.

Monday, 26 November 2012

Another Record Year of Enforcement Actions against Investment Advisers

The SEC has just released its most recent statistics on its enforcement program.  Numerous actions were filed against investment advisers in 2012.  Specifically, according to the release, the SEC filed 147 enforcement actions against investment advisers and investment companies, one more than the previous year’s record number.  Several of those actions resulted from the Enforcement Division’s investment adviser compliance initiative, which looks for registered investment advisers lacking effective compliance programs designed to prevent securities laws violations.

Friday, 16 November 2012

On October 17, the Securities and Exchange Commission (“SEC”) charged New Jersey-based Yorkville Advisors LLC (“Yorkville”), its founder Mark Angelo (“Angelo”), and its Chief Operating Officer and Chief Financial Officer, Edward Schinik, (“Schinik”) with intentionally overvaluing Yorkville’s assets under management and exaggerating Yorkville’s performance. The allegations state Angelo and Schinik made false statements to Yorkville’s investors and auditors concerning the value of certain investments in Yorkville’s funds; Yorkville’s valuation policies and use of third party valuation services; the value of the collateral underlying Yorkville’s investments, and the liquidity of Yorkville’s funds.1

Friday, 26 October 2012

After the Commodity Futures Trading Commission ("CFTC") rescinded certain exemptions, numerous advisers must now evaluate their registration requirements (please see our previous communique here on the rescission of Rule 4.13(a)(4) by the CFTC). For those that are required to register with the CFTC and become members of the National Futures Association ("NFA"), one of the most cumbersome elements of registration involves taking the Series 3 by the firm’s principals and associated persons.

Thursday, 11 October 2012

Andrew Bowden, Deputy Director of the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) and in charge of OCIE’s national examination program recently provided some new details[1] regarding OCIE’s examination program with respect to the over 1,400 newly-registered advisers to private funds.[2]

Mr. Bowden described the three phases of the current program as it relates to the SEC's approach towards these newly-registered managers as follows:

Thursday, 27 September 2012

New NFA Rules effective September 1, 2012 mandate the registration of “Swaps Firms” and “Swaps APs” and provide an exemption from Series 3 for Swap APs

New rules adopted by the National Futures Association (“NFA”) became effective on September 1, 2012 after being submitted for approval to the Commodity Futures Trading Commission (“CFTC”). The rules require that CFTC-registered firms trading swaps become approved as “Swaps Firms” by the NFA.  All Associated Persons (“APs”) of such “Swaps Firms” must also be approved as “Swaps APs”. Swap Firms are required to have at least one of their principals registered as an AP and approved by the NFA as a Swaps AP.  Swap APs are not, however, required to take the Series 3 (see our previous communiqué on the registration of APs and the Series 3 requirement here).  This exemption from the Series 3 requirement available to Swaps APs also applies to Swaps APs of other firms that would meet the de minimis trading test under Rule 4.13(a)(3) but for the inclusion of swaps in the calculation of the applicable thresholds (for an explanation of the de minimis test, see our previous communiqué here - the test is also explained below).  The new NFA rules can be found here

Tuesday, 04 September 2012

The Securities and Exchange Commission (“SEC”) has proposed amendments to Rule 506 of Regulation D to allow the use of general solicitation and advertising in connection with offerings made under the rule to purchasers who are accredited investors.  These amendments are in response to a mandate by Congress under the Jumpstart Our Business Startups Act (“JOBS Act”), which was enacted on April 5, 2012.  A link to the proposing rule release is here.  The SEC has allowed a 30-day comment period before it enacts the final rule.

Friday, 31 August 2012

The Private Investment Funds Subcommittee of the New York State Bar Association recently organized a meeting on the Securities and Exchange Commission’s (“SEC”) risk-based examination program.  The meeting was led by Andrew Bowden, the Head of the Investment Advisers National Examination Program of the SEC’s Office of Inspections and Examinations (“OCIE”) and was co-presented by Janaya Moscony, the President of SEC Compliance Consultants, Inc. (“SEC3”) and Barry Barbash, the head of the investment management group of Willkie Farr & Gallager and a former Director of the SEC’s Division of Investment Management.

Wednesday, 01 August 2012

How to Design an Appropriate Electronic Communications Review

A frequent question we receive from both established and newly registered advisers concerns the proper review of electronic communications. We understand that no one really wants to read someone else's private and sometimes very personal emails. But, it has to be done and your "supervised persons" should be well aware that there can be no expectation of privacy when using your business' electronic communication platforms (emails, instant messaging, text, etc).

Thursday, 19 July 2012

Adequate Supervision

Section 203(e)(6) of the Investment Advisers Act of 1940 permits the SEC to bring an enforcement action against a registered investment adviser or an associated person who, among other things, has failed to supervise a person who commits a violation, if such person is subject to their supervision.

Wednesday, 20 June 2012

State Law versus Federal: Who will protect the CCO?

We may not be the first to tell you, but it is important to note that the challenges presented to those holding the CCO title and their duty to supervise recently became more complicated following a decision of the New York Court of Appeals which upheld last month the right of a hedge fund manager to terminate a CCO (who was an at-will employee) for allegedly voicing objections over inappropriate securities trading by his employer (Sullivan v. Harnisch).

Tuesday, 12 June 2012

Private fund advisers that will be required to register with the Commodity Futures Trading Commission (“CFTC”) and become members of the National Futures Association (“NFA”) by the end of the year due to the rescission of the CFTC exemption from registration previously available under Rule 4.13(a)(4) of the Commodities Exchange Act ("CEA") should ensure that their associated persons (“APs”) pass the Series 3 examination.

Wednesday, 23 May 2012

The question on the minds of all new registrants. We now have the answer. Many should expect and prepare to be examined potentially this coming fall. At the GAIMOPs conference on April 23, 2012, Carlo di Florio, the Director of the Office of Compliance Inspections and Examinations (“OCIE”), indicated that private fund advisers could expect to see a series of exams this coming fall.

Thursday, 17 May 2012

President Obama signed into law the Jumpstart Our Business Startups Act ("JOBS Act") which liberalizes the way private placements are conducted and allows general solicitation and general advertising.

Some key aspects of the JOBS Act are:

Monday, 09 April 2012

On February 9, 2012, the Commodity Futures Trading Commission ("CFTC") rescinded certain exemptions from registration previously available to private funds and SEC-registered investment companies that trade in commodity interests.

Most importantly, the CFTC rescinded the exemption from "commodity pool operator ("CPO") registration set forth in Rule 4.13(a)(4) under the Commodities Exchange Act ("CEA"), which was widely used by 3(c)(7) funds. The exemption allowed funds offered to "qualified eligible persons" ("QEPs"), which include "qualified purchasers", and their CPOs (i.e. the general partners of the funds) to do unlimited trading in futures and options without registering with the CTFC.

Wednesday, 14 March 2012

Forms SLT, SHC and S are part of the reporting requirements of Treasury International Capital ("TIC") reporting system administered by the U.S. Department of the Treasury. The TIC reporting system collects data for the United States on cross-border portfolio investment flows and positions between U.S. residents (including U.S.-based branches of firms headquartered in other countries) and foreign residents (including offshore branches of U.S. firms).

Friday, 24 February 2012

SEC Associate Director Robert Plaze's April 8th letter to David Massey, President, North American Securities Administrators Association, Inc. ("NASAA") states, "We anticipate that the Commission will complete its implementing rulemaking by July 21, 2011 in accordance with the Dodd-Frank Act, but expect in connection therewith that the Commission will consider providing additional time for investment advisers affected by these provisions to come into compliance."

Tuesday, 26 April 2011

Pay to play is the practice of making campaign contributions and related payments to elected officials in order to influence the awarding of lucrative contracts for the management of public pension plan assets and similar government investment accounts. Advisers Act Rule 206(4)-5 prohibitions are intended to capture not only direct political contributions by investment advisers, but also indirect pay to play arrangements.

Monday, 14 March 2011

We believe the beginning of 2011 is a suitable time to address several key issues facing investment advisers to private funds as they come to grips with the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") and ultimately, registration with the Securities Exchange Commission ("SEC") or applicable states.

Thursday, 13 January 2011

The holidays provide the opportunity for us take a step back from the routine, remind ourselves of our priorities, and gain fresh perspective. Instead of being forced back to work and feeling completely apprehensive about returning to our professional duties, we can actually view the process with an appreciation for renewed perspective.

Monday, 03 January 2011

The effective date for the amended rules pertaining to the new ADV Form Part 2 is today, October 12th, 2010. Fortunately existing advisers have some lead time to comply. That being said, most must meet the requirements by March 31st, 2011[1] which will be before us in no time.

Tuesday, 12 October 2010

Since the adoption of the Private Fund Investment Advisers Registration Act of 2010 on July 21, 2010, we have only registered a handful of private fund advisers with the SEC. However, we have or are currently assisting many private fund advisors with developing a compliance program that will satisfy the Investment Advisers Act of 1940.

Tuesday, 28 September 2010

Our Guide to SEC Registration for Private Fund Investment Advisers is a comprehensive guide to the registration process and ongoing compliance requirements after registration. The guide also includes a detailed discussion of the required disclosure in Form ADV Part II, based on the SEC's newly adopted ADV requirements.

Monday, 26 July 2010

As widely reported and commented upon, on April 16, 2010, the Securities and Exchange Commission ("SEC") brought charges against Goldman, Sachs & Co. ("Goldman Sachs") for allegedly "defrauding investors by misstating and omitting key facts about a financial product tied to subprime mortgages as the U.S. housing market was beginning to falter". The SEC claims Goldman Sachs failed to disclose vital information about an investment opportunity to investors.

Tuesday, 04 May 2010

The Securities and Exchange Commission ("Commission") recently voted to amend Regulation SHO, the short selling rule under the Securities Exchange Act of 1934 ("the Rule"). The effective date of the rule is May 10, 2010 and the compliance date is November 10, 2010. The amendments, and the process leading up to the vote itself, were not without significant debate, controversy and consternation among market participants.

Tuesday, 20 April 2010

Recent comments by various members of the Securities and Exchange Commission ("SEC"), including its Chairman, Mary L. Schapiro, have pointed to a harmonization approach to regulation of financial industry firms under the purview of the SEC. Discussions also have revolved around tweaking the SEC examination program towards a more holistic market focus and bringing various market participants, who are currently operating outside the tent of the SEC, under the regulator's oversight.

Monday, 01 March 2010

Tu·mul·tu·ous (adjective) marked by violent or overwhelming turbulence or upheaval. Imagine for a moment a European bullet train speeding at 250 km/hr along the Washington - Boston Northeast Corridor which was designed to support the Acela Express with an average speed of 140 km/hr. Many hedge fund managers may be feeling the same way; that they are on a tumultuous ride. Who can blame these managers?

Friday, 05 February 2010

2009 was a year of turmoil in the financial markets and the economy in general. With abuses and fraud making headlines and regulators being partly blamed for the economic issues, individuals in the financial community seem to be awaiting a wave of regulatory self-protective backlash consisting of potentially unnecessary, and ultimately, ineffective regulations.

Tuesday, 05 January 2010


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Pre-Dating & Back-Dating are Equally Risky

The SEC today suspended three accountants formerly of BDO USA LLP for improper professional conduct during its 2013 audit of AmTrust Financial Services Inc., an exchange-listed insurance company. According to the... read more »

Fiduciary Duty

On Friday, September 28, 2018 the SEC charged LendingClub Asset Management (LCA) and its former president Renaud Laplanche with fraud for improperly using fund money to benefit LendingClub Corporation (LendingClub),... read more »

Exciting Summer Project -- Dig Into Some Sand or Dig Into Your Firm's Best Ex Pr…

The Office of Compliance Inspections and Examinations (OCIE) issued a risk alert July 11 targeting investment advisers’ most common deficiencies with regard to their best execution obligations under the Investment... read more »

SEC Adopts Fund Liquidity Reporting and Disclosure Changes

The final week of June was a busy one for SEC releases following the SEC’s June 28th open meeting. Among these was a revisit of Rule 22e-4 under the Investment... read more »

More SEC Settlements - This Time Form PF Filing Deficiencies

On June 1st, the SEC announced settlements with 13 RIAs who repeatedly failed to file Form PF reports. Most of these firms never filed over the review period (2012 through... read more »

Two Recent Enforcement Actions Against Private Fund Advisers

The industry should not misinterpret the SEC’s 2018 National Exam Program Priorities as a shift away from private fund advisers. As discussed during the SEC’s recent National Compliance Outreach Seminar... read more »


Chief Compliance Officer Roundtable: Breakfast Briefing - November 8, 2018

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Dorsey PF 2018 Symposium

When: September 26, 2018 (8:30 am - 6 pm Where: Dorsey & Whitney LLP | 51 W. 52nd Street | New York, NY 10019 Directions > SEC3’s President, Janaya Moscony will join...

Chief Compliance Officer Roundtable: Breakfast Briefing - June 14, 2018

When: June 14, 2018 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone: 212.885.5000 Schedule: 9:00-9:30am - Networking...

Webinar: 2018 SEC Exam Priorities & Recent Exam Highlights

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Chief Compliance Officer Roundtable: Breakfast Briefing - February 7, 2018

When: February 7, 2018 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone: 212.885.5000 Schedule: 9:00-9:30am - Networking...

Upcoming Events - September & October 2017

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May 23, 2017 - Webcast: WannaCry Ransomware: Were You Really Protected or Just L…

When: Tuesday, May 23rd, 2017 | Schedule: 12pm - 1pm EST Who: Paul Caiazzo, CEO and Co-Founder, TruShield Security Solutions Michael Brice, Founder, BW Cyber Services John Lukan, Managing Director, SEC Compliance Consultants, Inc. We...

June 14, 2017 - Compliance Breakfast Briefing

8:30-9:00am - Networking and Continental Breakfast 9:00-10:30am - Program Location: Willkie Farr & Gallagher LLP | 600 Travis Street | Suite 2310 | Houston, TX Barry Barbash from Willkie Farr & Gallagher LLP,...

June 13, 2017 - Compliance Breakfast Briefing

8:30-9:00am - Networking and Continental Breakfast 9:00-10:30am - Program Location: Haynes and Boone, LLP | 2323 Victory Avenue | Suite 700 | Dallas, TX 75219 Validated parking is available in the garage attached...

May 31, 2017 - Chicago

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May 17, 2017 (NYC WIMF)

This event is by invitation only. Please email to learn more.

May 15, 2017 (NYC Chief Compliance Officer Roundtable)

9:00-9:30am - Networking and Continental Breakfast 9:30-11:00am - Program Location: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone:...

Webcast: The Most Insidious Cybersecurity Threat Is Also The Least Understood

When: Tuesday, April 25th | Schedule: 12pm - 1pm EST Who: Paul Caiazzo, CEO and Co-Founder, TruShield Security Solutions Michael Brice, Founder, BW Cyber Services John Lukan, Managing Director, SEC Compliance Consultants, Inc. Ransomware, the...

CCO Liability (Part III): Managing Liability Webinar

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Webinar: CCO Liability (Part III): Managing Liability: Navigating Indemnities an…

When: Tuesday, February 21, 2017 Schedule: 11:00am ET / 10:00am CT / 9:00am MT / 8:00am PT / 7:00am AT Description of Webinar: The National Society of Compliance Professionals is pleased to host...