The Securities and Exchange Commission (“SEC”) has noted that it will focus its attention on wrap fee programs as stated in the recently released 2017 examination priorities list. Additionally, the SEC has noted that any time an adviser relies on the performance of a subadviser or third party, appropriate due diligence should be conducted on the third party’s performance to substantiate the accuracy of the information.
Because of the increased regulatory attention on wrap fee programs, firms need to ensure that their compliance programs are ready for an examination, which includes making sure that records are available, investment performance returns are calculated properly, appropriate fees are calculated and applied to performance, proper disclosures are provided to clients in marketing materials, and, if a firm is GIPS® compliant, it has followed the requirements of the GIPS standards.
Please join Crista DesRochers, Managing Director at ACA Performance Services, and Michelina Cuccia, Director at ACA Compliance Group on February 22 for a discussion on minimizing regulatory risk and best practices related to wrap fee programs from both an SEC and GIPS standards perspective. The webcast will focus on:
- recent SEC cases and related findings;
- record keeping requirements;
- proper due diligence to rely on third party data;
- performance calculations and related wrap fees;
- marketing materials and disclosures;
- GIPS compliance requirements and best practices; and
- UMA accounts.
Throughout the webcast, the panelists will answer questions and respond to comments from attendees.
Who should attend?
This webcast is intended for firms that participate in wrap fee programs and specifically for individuals with oversight of compliance and/or investment performance and distribution (CCOs and COOs, for example).
To register, click here.