These are just some of things we raised in our newsletter update earlier this summer and thought that some of our wider contacts might be interested in what we are/were looking at.
SFC Items of Interest
Conflicts of Interest, Expense and Fee Disclosures
Just to highlight as an area of continuing regulatory focus for Asset Managers
Cybersecurity (SolarWinds, Fortinet, Microsoft Exchange)
Check in with your security vendor if you have not done your annual review
Business Continuity - Vaccination Stance - What is yours? Have you wrote it down?
Data Protection - Data Leak management - Continued Focus
Electronic Data Service Providers - Are we there yet? What is next?
Bank Account Controls – Solutions if necessary being adapted
Market Misconduct – Of ongoing interest
Company Disclosures - Market Discipline
Ramp and Dump
Boiler Rooms
LIBOR -Deadlines are visible - What is your exposure?
Liquidity, Leverage and Counterparty Risk
Market Correction/Market Liquidity Impact
Just because you have survived does not mean your process is robust
OTC Derivatives - Continuing Global Developments
ESG Parts 1, 2, and 3
1 - Firm Obligations - Environmental and Social Policy
2 - Fund Obligations - All Funds
3 - Funds with ESG Objective’s Obligations (Authorised, Registered, Listed)
OFC – If you are interested in launching HK domiciled funds there is support
FMCC Review – Probably time to review adequacy of your risk process
AML Oversight Process - Risk Assessment Process -Increasing depth
Continuing Professional Training– 2020/21 (2 Year Deadline approaches)/2022 - Double Time -See our update
SEC/US Items of Interest
Conflicts of Interest, Expense and Fee Disclosures - Same as SFC
Cybersecurity (SolarWinds,Fortinet, Microsoft Exchange)
Check in with your security vendor if you have not done your annual review
Market Misconduct
Company Disclosures
Pump and Dump
Medical MNPI
ESG
LIBOR
Advertising Rule Changes
Performance
Sanctions Management
Change of Guard at SEC/Change of Stance
Check in with US Consultant
EU and UK Relevant Matters
Cross Border Financial Services – Check out developing AIMA resources
Reverse Solicitation – ESMA
MiFID (Commission Unbundling)
China Relevant Matters
Sanctions Politics (US/China/EU and Vice Versa) – 2nd August Implementation
Cybersecurity/Data Privacy vs Rest of World
You will note that we did not mention SPACs or Crypto Assets. We are not ignoring them, we just find that not everyone is interested in speaking about them. We also spent a good bit of time looking at the quarantine exemptions but ultimately concluded that there is a high bar in terms of obtaining an exemption and a high risk of breaching the conditions.
Please speak to your consultant about any of the issues raised.
Comments