Because of this potential, funds’ policies and procedures should be crafted to ensure appropriate monitoring of dilution and to prevent or discourage abusive trading practices using as-of trades. A high distribution rate largely comprised of return of capital might cause investors to erroneously conclude that the fund is generating a high total return. 1. We use cookies to improve your browsing experience on our website. The information included in this website has been prepared for and is intended for viewing by a global audience. The total proposed credit is reduced at a rate of 5% of adjusted gross income above $75,000 ($112,500 for head of household filers and $150,000 for married joint returns). States would be permitted to expand eligibility to provide unemployment compensation to workers who are not normally eligible for benefits, so long as their unemployment was connected to the COVID-19 pandemic, as determined by the state and the Department of Labor. Nonresident aliens and dependents claimed by another taxpayer are not eligible. PPP loans can be as large as 250% of a business’s average monthly payroll costs over the last 12 months, not to exceed $10 million; salaries over $100,000 are not counted as payroll costs. The FPUC would be paid in addition to and at the same time as regular state or federal UC benefits. Allows over-the-counter medicines and drugs to be reimbursed by a health FSA, HSA, archer MSA, or HRA without a prescription for expenses incurred after December 31, 2019. Employers with 100 or more employees can only apply the credit to employees furlough whose wages are continued for business closure relative to COVID-19. 8 Certain relevant laws/rules in this area include Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and SRO rules regarding supervision, registration, non-cash compensation and sales practices. In several examinations of broker-dealers that sold collateralized mortgage obligations (CMOs) and asset backed securities to retail customers, examiners identified deficiencies in the disclosures provided to customers and in other areas.7 The broker-dealers examined had sold some of the most complex and riskiest classes of securities to their retail customers. PPP loans can be as large as 250% of a business’s average monthly payroll costs over the last 12 months, not to exceed $10 million; salary compensation in excess of $100,000 are not counted as payroll costs. maintaining sufficient insurance and financial liquidity to prevent any interruption to the performance of compliant advisory services. Some firms had to physically retrieve their server from their original office space in the days/weeks after the hurricane. Examiners found that many firms did not close out fail to deliver positions within thirteen consecutive settlement days (though the number of incidents found was quite small). The majority of the advisers examined during these risk-focused examinations claimed that they had presented their performance in a manner that was consistent with the CFA Institute’s performance presentation standards, though only one was in full compliance. A Service Bulletin (S.B.) Employers with 100 or fewer employees can take credit for all employees. The SEC staff conducts compliance examinations of SEC-registered investment advisers, investment companies, broker-dealers, and transfer agents to determine whether these firms are in compliance with the federal securities laws and rules, and to identify deficiencies and weaknesses in compliance and supervisory controls. Some firms allowed additional short sales in a security without pre-borrowing when a fail to deliver position remained for more than 13 consecutive settlement days. These firms disseminated information which did not appear to provide balanced and complete disclosure of the risks inherent in the CMOs that were sold. In addition, about a third of the advisers lacked any compliance policies and procedures governing marketing and performance advertising, and others maintained procedures that did not appear to be effective. We recommend that you as an employer review the unemployment benefits offered in your states, along with the expansions provided by the CARES Act to help you understand the best path forward for your employees and your business. While the requirements of compliance may appear difficult at first, we’ve compiled a helpful guide to the most important things you need to know about SMS compliance. 10 Certain relevant laws/rules in this area include Rule 17a-3(a)(2) (books and records) of the Exchange Act, and SRO rules regarding standards of commercial honor and principles of trade, supervision and sales practices. We note that this document was prepared by the SEC staff. Reimbursable employers would not have charges against their accounts for these benefits. Examiners also found a lack of supervisory procedures to review the adequacy of disclosures made to investors in connection with the sale of CMOs, indications of recommendations that retail customers purchase CMOs that appeared to be unsuitable (e.g., transactions that were inconsistent with the customer’s stated investment objectives and, in some cases, represented a significant portion of the customer’s liquid assets), and in some instances, undisclosed markups that appeared to be excessive. PPP loans must be made between the date of enactment and June 30, 2020. Employers who apply for and receive Paycheck Protection Program loans are not eligible for the credit. Examiners also found instances where as-of processing was unnecessarily delayed a day or more after receiving the as-of transaction request in good order (or becoming aware that a processing error required an as-of transaction). We note that this document was prepared by the SEC staff.1. Alert Line. In July of 2009, Organizational Development Solutions Inc. was contracted as the compliance auditors to monitor and provide guidance in the use of minority and women owned businesses as well as the utilization of Indiana and Northwest Indiana businesses with respect to projects which are being funded through the use of RDA dollars. they have 50% less cash receipts for the same period the prior year, unless the quarter prior to the credit period has increased gross receipts of 80% the prior year. For example, inadequate policies and procedures did not: Some examples of policies and procedures in place at the firms with fewer deficiencies included: About a quarter of the advisers examined used some type of “hypothetical return” number in their performance claims, though most coupled the hypothetical return with supplemental explanatory disclosure. Employers are eligible to defer 100% of their Employer Social Security tax for amounts due after March 27 through December 31, 2020. State UC programs would be fully reimbursed for the cost of administering the supplement and for the cost of the supplement itself. A very common deficiency was with respect to advisers’ inappropriate claims of compliance with the CFA Institute’s performance presentation standards. As a result, those transactions bypassed crucial aspects of the firms’ supervisory systems and procedures. The views expressed herein are those of the staff of the Office of Compliance Inspections and Examinations, in coordination with other SEC staff, including in the Divisions of Investment Management and Market Regulation, and do not necessarily reflect the views of the Commission or the other staff members of the SEC.


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