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Page 1: FEATURED TOPICS: and Part 2 • Whistleblower Rule Social Media …frontlinecompliance.com/wp-content/uploads/2015/02/IAA... · 2018-08-10 · FEATURED TOPICS: Form ADV Part 1 and

FEATURED TOPICS: Form ADV Part 1 and Part 2 • Whistleblower Rule Social Media • CCO LiabilitySEC Exams • Enforcement Issues Pay to Play • ERISA • Code of Ethics Annual Review

SPONSOR SUPPORTER

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The regulatory developments during the past year have had a profound impact on the investment advisory profession. As a result of the Dodd-Frank Act, the SEC’s enforcement tools and resources have been enhanced. Several studies have been issued that may lead to increased regulation and oversight of investment advisers. There are new registration, reporting, and recordkeeping obligations for private fund advisers, including the new Form PF.

In addition, lawmakers are considering legislation that would establish a self-regulatory organization for investment advisers. Other regulatory changes include the implementation of changes to Form ADV Part 2, significant revisions to Form ADV Part 1, and new pay to play requirements.

The Investment Adviser Association is pleased to announce the Investment Adviser Compliance Con-ference on March 8-9, 2012. To make sure you are up to date on relevant regulatory changes and to prepare you for what lies ahead, the conference will focus on “Best Practices in a Changing Regulatory Environment,” and will address need-to-know issues that specifically affect investment advisers, includ-ing industry best practices for compliance and legal professionals. The distinguished roster of speak-ers includes SEC staff, investment adviser chief compliance officers and in-house counsel, and other knowledgeable experts. Our comprehensive two-day program is designed to provide the most current information available on the changing regulatory landscape for investment advisers and to assist you in gaining a clearer understanding of what is necessary to maintain a successful compliance program.

Topics will include: the new Whistleblower rule, Form ADV Part 1 and Form ADV Part 2, SEC exami-nations, enforcement issues, CCO liability, social media, and possible self-regulation of the advisory profession. You also will participate in breakout sessions to discuss today’s hot topics (including private funds, ERISA, pay to play, codes of ethics, insider trading, and annual review) as well as participate in CCO workshops tailored to the unique issues facing firms of your size. In addition, you will hear about changing SEC priorities for its inspection and examination program for investment advisers.

The conference will provide you with practical materials and resources, as well as an excellent opportunity to network with your peers, attorneys, consultants, and service providers in order to strengthen and grow your business.

We look forward to seeing you in March.

Sincerely,

David G. TittsworthExecutive Director and Executive Vice President Investment Adviser Association

IAA INVESTMENT ADVISERCOMPLIANCE CONFERENCEBest Practices in a Changing Regulatory Environment

March 8-9, 2012Crystal Gateway MarriottArlington, Virginia(Washington, DC Metro Area)

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MARCH 8-9, 2012 3

BEST PRACTICES in a Changing Regulatory Environment

Snapshot: Agenda

Thursday, March 8

7:15 – 8:30 am Registration and Continental Breakfast8:30 – 8:45 am Welcome Remarks8:45 – 9:15 am Keynote Address9:15 – 10:15 am The Evolution of Compliance: Structuring a Robust and Effective Compliance

Program 10:15 – 10:45 am Break10:45 – 11:45 am What the New Whistleblower Regulations Mean for Advisers11:45 – 12:45 pm CCO Liability12:45 – 2:00 pm Luncheon Address2:00 – 3:00 pm Breakout Sessions: CCO Workshops (1) Small Firms (AUM under $1 billion) (2) Medium Firms (AUM $1 – $10 billion) (3) Large Firms (AUM over $10 billion)3:00 – 3:30 pm Break3:30 – 4:15 pm Breakout Sessions: (1) Hot Topics for Private Fund Advisers (2) ERISA Basics (3) Political Contributions and Pay to Play: Considerations for Navigating the

Regulatory Requirements (4) Code of Ethics4:15 – 4:30 pm Break4:30 – 5:15 pm Breakout Sessions: (1) Additional Hot Topics for Private Fund Advisers (2) ERISA Hot Topics (3) SEC Enforcement Issues for Advisers (4) Annual Review 5:15 – 7:15 pm Cocktail Reception

Friday, March 9

8:00 – 9:00 am Compliance Roundtable Breakfast9:00 – 9:30 am Self-Regulation of the Investment Advisory Profession9:30 – 10:45 am Form ADV Part 1 and Part 2: Your Registration and Disclosure Documents 10:45 – 11:15 am Break11:15 – 12:15 pm Social Media Issues12:15 – 1:45 pm Luncheon Address1:45 – 2:45 pm SEC Exams 2:45 pm End of Conference

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4 MARCH 8-9, 2012

7:15 – 8:30 am Registration and Continental Breakfast

8:30 – 8:45 am Welcome Remarksu David G. Tittsworth, Executive Director and Executive Vice President, IAA

8:45 – 9:15 am Keynote Address

9:15 – 10:15 am The Evolution of Compliance: Structuring a Robust and Effective Compliance Program

Compliance for investment management firms has evolved considerably during the past 15 years. This panel will examine how the role of compliance professionals has been transformed as the number and complexity of regulatory requirements have proliferated and the business of investment management has changed. This panel also will look ahead to understand how the role of compliance professionals may evolve over time and offer suggestions to consider in structuring a robust and effective compliance program.

u David G. Tittsworth, Executive Director and Executive Vice President, IAA, Moderator u Thomas D. Giachetti, Shareholder, Stark & Stark u Christopher Jackson, Senior Vice President and General Counsel, Calamos Advisors,

LLC u Robert E. Plaze, Deputy Director, Division of Investment Management, U.S. Securities

and Exchange Commission

10:15 – 10:45 am Break

10:45 – 11:45 am What the New Whistleblower Regulations Mean for Advisers Investment advisers face significant new challenges with the SEC’s adoption of the

whistleblower regulations. Under the new rules, persons who provide the SEC with information leading to a successful enforcement action in which more than $1 million is recovered are entitled to an award of 10 to 30 percent of that amount. This panel will review the key implications of the new rules and discuss best practices for complying with the requirements.

u Valerie M. Baruch, Associate General Counsel, IAA, Moderator u Richard Marshall, Partner, Ropes & Gray LLP u Rosa Licea-Mailloux, SVP, Associate General Counsel, Natixis Global Associates u Sean McKessy, Chief, Office of the Whistleblower, U.S. Securities and Exchange

Commission

A G E N D A • T H U R S D AY, M A R C H 8 D AY 1

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MARCH 8-9, 2012 5

11:45 – 12:45 pm CCO Liability Chief compliance officers continue to be named in numerous SEC enforcement cases.

Has the responsibility of CCOs increased or changed significantly in the past few years, or are these cases based on unique facts? This panel will explore these enforcement cases, and CCOs will share their perspective on what CCO liability really means in practice.

u Jennifer S. Choi, Associate General Counsel, IAA, Moderator u James E. Anderson, Partner, WilmerHale u Mary E. Keefe, Managing Director and Director of Compliance, Nuveen Asset

Management u Christine Carsman, Senior Vice President and Deputy General Counsel, Affiliated

Managers Group, Inc. u Robert E. Plaze, Deputy Director, Division of Investment Management, U.S. Securities

and Exchange Commission

12:45 – 2:00 pm Luncheon Addressu Eileen Rominger, Director, Division of Investment Management, U.S. Securities and

Exchange Commission

2:00 – 3:00 pm Breakout Sessions: CCO Workshops These sessions will focus on challenges faced by advisers to ensure that their

compliance program continues to be dynamic and tailored to their business model and size. The breakout sessions offer an opportunity for attendees to discuss various compliance issues within a smaller group setting, including risk management, compliance controls, forensic testing, and annual reviews.

Small Firms (AUM under $1 billion) u Lorna A. Schnase, Attorney at Law, Moderator u Joseph T. Seminetta, President, Senior Portfolio Manager and Chief Compliance

Officer, Premier Asset Management LLC u Ralph Lipford, Managing Member, Botty Investors LLC u Susan Rudzinski, Compliance Director, Convergent Capital Management LLC

REGISTER ONLINE TODAY: www.investmentadviser.orgu IAA Members save up to $300

D AY 1 A G E N D A • T H U R S D AY, M A R C H 8

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6 MARCH 8-9, 2012

Medium Firms (AUM $1 – $10 billion)

u Alan P. Goldberg, Partner, K&L Gates LLP, Moderator u Wendy Fox, Vice President, Chief Compliance Officer, Ariel Investments, LLC u Wendy Nunez, Chief Compliance Officer and Partner, Champlain Investment Partners

LLC u Randi Lederman, Compliance Officer, Rockefeller Financial & Co., Inc.

Large Firms (AUM over $10 billion)

u Kenneth Berman, Partner, Debevoise & Plimpton LLP, Moderator u John Gilner, Vice President and Chief Compliance Officer, T. Rowe Price Associates, Inc. u Nancy Morris, Chief U.S. Regulatory Counsel, Allianz Global Investors of America L.P. u Lawrence Lafer, Chief Compliance Officer, BNY Mellon Asset Management

3:00 – 3:30 pm Break

3:30 – 4:15 pm Breakout Sessions

(1) Hot Topics for Private Fund Advisers This panel will discuss the new SEC registration, reporting, and recordkeeping

obligations for private fund advisers, including the reporting requirements in Form PF, Form ADV, and new Form 13H (Large Trader), as well as other compliance obligations.

u Karen L. Barr, General Counsel, IAA, Moderator u David Vaughan, Partner, Dechert LLP u Kenneth Linton, Senior Associate General Counsel, Franklin Templeton Investments u Stephen McShea, General Counsel and Chief Compliance Officer, Larch Lane

Advisors LLC u Tram N. Nguyen, Branch Chief, Private Fund Adviser Regulation, Office of Investment

Adviser Regulation, U.S. Securities and Exchange Commission

(2) ERISA Basics This panel will discuss ERISA basics for investment advisers. Topics to be covered

include an overview of ERISA, who is considered to be a fiduciary under ERISA, basic ERISA fiduciary duties, and prohibited transactions and exemptions.

u Kathy D. Ireland, Associate General Counsel, IAA, Moderator u William A. Schmidt, Partner, K&L Gates LLP u Anne S. Tuttle, Executive Vice President and General Counsel, Financial Engines, Inc.

A G E N D A • T H U R S D AY, M A R C H 8 D AY 1

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MARCH 8-9, 2012 7

(3) Political Contributions and Pay to Play: Considerations for Navigating the Regulatory Requirements

Compliance with the SEC’s pay to play rule limits political contribution and marketing activities by investment advisers (and some of their employees) that manage money for state or local entities. In addition, many states and municipalities have become increasingly active in this area and are imposing greater restrictions on these activities. This panel will discuss how investment advisers should navigate through the complex regulatory framework, including discussing best practices and policies and procedures to help comply with political contribution and third-party solicitor limitations.

u Monique S. Botkin, Assistant General Counsel, IAA, Moderator u Ki P. Hong, Partner, Skadden Arps LLP u Nancy Morris, Chief U.S. Regulatory Counsel, Allianz Global Investors of America L.P. u Staff of Division of Investment Management, SEC

(4) Code of Ethics An adviser’s code of ethics must reflect the firm’s and its employees’ fiduciary

obligations as well as their obligations to comply with federal securities laws. This panel will discuss how to focus effectively on the highest-risk areas and will discuss best practice suggestions for monitoring, testing, administering, and enforcing the code of ethics and its securities reporting requirements for access persons, including appropriate sanctions for code violations.

u Paul D. Glenn, Special Counsel, IAA, Moderator u Michael K. Wolensky, Partner, Schiff Hardin LLP u Lori Renzulli, Chief Compliance Officer and Chief Counsel, Harding Loevner LP u John H. Walsh, Partner, Sutherland LLP

4:15 – 4:30 pm Break

4:30 – 5:15 pm Breakout Sessions

(1) Additional Hot Topics for Private Fund Advisers This panel will discuss hot topics for private fund advisers that were not addressed in

the first Private Fund Advisers panel, including whether private fund advisers will need to register with the CFTC, and U.S. Treasury Department reporting requirements (e.g. FBAR, FormSLT).

u David Vaughan, Partner, Dechert LLP, Moderator u Cary J. Meer, Partner, K&L Gates LLP u Kenneth Linton, Senior Associate General Counsel, Franklin Templeton Investments u Stephen McShea, General Counsel and Chief Compliance Officer, Larch Lane

Advisors LLC

D AY 1 A G E N D A • T H U R S D AY, M A R C H 8

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8 MARCH 8-9, 2012

(2) ERISA Hot Topics This panel is intended for attendees who have a basic working knowledge of ERISA

and would like to gain a greater understanding of the latest developments. Topics to be discussed include the Department of Labor regulations taking effect in 2012 requiring advisers to provide certain disclosures to plan sponsors. In addition, the panel will cover regulations that require certain investment disclosures to plan participants, DOL’s proposed changes to the definition of fiduciary in the context of investment advice, final rules implementing Pension Protection Act provisions on participant-level investment advice, and guidance concerning prohibited transactions.

u Kathy D. Ireland, Associate General Counsel, IAA, Moderator u William A. Schmidt, Partner, K&L Gates LLP u Anne S. Tuttle, Executive Vice President and General Counsel, Financial Engines, Inc. u Joe Canary, Director, Office of Regulations and Interpretations, Employee Benefits

Security Administration, U.S. Department of Labor (INVITED)

(3) SEC Enforcement Issues for Advisers The panelists will discuss the latest trends in enforcement actions brought by the SEC

against investment advisers. Topics to be addressed include cases involving insider trading, conflicts of interest, compliance violations, performance advertising, and improper fees. Hear from industry experts about lessons to be learned.

u Lori A. Martin, Partner, WilmerHale, Moderator u Mark D. Perlow, Partner, K&L Gates LLP u Robert Kaplan, Co-Chief, Asset Management Unit, Division of Enforcement, U.S.

Securities and Exchange Commission

(4) Annual Review The annual review is even more critical for advisers because of the many regulatory

and market changes underway. This panel will discuss how investment advisers can best utilize their resources to conduct an effective annual review of their compliance program.

u Stephanie L. Darling, Principal, The Law Office of Stephanie Darling, Moderator u Pat H. Swanson, Managing Director and Chief Compliance Officer, King Investment

Advisers, Inc. u Mary T. Lomasney, Managing Director, BNY Mellon Asset Management u Mavis Kelly, Assistant Director, Office of Compliance Inspections and Examinations,

U.S. Securities and Exchange Commission

5:15 – 7:15 pm Cocktail Reception

A G E N D A • T H U R S D AY, M A R C H 8 D AY 1

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MARCH 8-9, 2012 9

8:00 – 9:00 am Compliance Roundtable Breakfast

8:30 – 9:30 am Self-Regulation of the Investment Advisory Profession This panel will discuss the latest developments with respect to possible self-

regulation of the investment adviser profession.

u David G. Tittsworth, Executive Director and Executive Vice President, IAA u Neil Simon, Vice President for Government Relations, IAA

9:30 – 10:45 am Form ADV Part 1 and Part 2: Your Registration and Disclosure Documents

This extended panel will address the amendments to Part 1 and Part 2 of Form ADV. The panelists will focus on lessons learned from the first filing of the amended Form ADV Part 2, as well as practical tips in drafting the disclosure document. The panelists will also address the revised Form ADV Part 1 that all registered investment advisers will be required to file by March 30, 2012, including the calculation of regulatory assets under management.

u Valerie M. Baruch, Associate General Counsel, IAA, Moderator u Mari-Anne Pisarri, Partner, Pickard & Djinis LLP u Lewis Collins, Senior Vice President and Senior Counsel, Affiliated Managers

Group, Inc. u Daniel Kahl, Assistant Director, Office of Investment Adviser Regulation, U.S.

Securities and Exchange Commission

10:45 – 11:15 am Break

11:15 – 12:15 pm Social Media Issues Social networking sites offer a new and powerful medium to communicate with and

educate clients, as well as to network with other firms. Investment advisers must consider numerous regulatory implications when using these sites. This panel will address how social networking sites can be employed effectively by investment advisers and their employees. The panel will also explore the relevant regulatory issues, including advertising and books and records requirements that CCOs must consider in permitting their use by employees and the firm.

u Paul D. Glenn, Special Counsel, IAA, Moderator u Beth D. Kiesewetter, Associate, Morgan Lewis LLP u Lisa Sheeler, Vice President and Assistant General Counsel, MFS Investment

Management u Melissa A. Roverts, Branch Chief, Division of Investment Management, U.S.

Securities and Exchange Commission

A G E N D A • F R I D AY, M A R C H 9D AY 2

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10 MARCH 8-9, 2012

12:15 – 1:45 pm Luncheon Address u Carlo di Florio, Director, Office of Compliance Inspections and Examinations, U.S.

Securities and Exchange Commission

1:45 to 2:45 pm SEC Exams The SEC is facing continued pressure to refocus and leverage its examination

resources. In addition, the agency must be prepared for new private fund adviser registrants. This panel will explore how the SEC will use its resources, changes to the examination program, and the areas of focus for the SEC’s examination staff.

u Elizabeth M. Knoblock, Partner, Mayer Brown LLP, Moderator u Thomas A. Biolsi, Principal, PricewaterhouseCoopers, LLC u Robert T. Burns, General Counsel, Putnam Investment Management, LLC u Norman Champ, Deputy Director, Office of Compliance Inspections and

Examinations, U.S. Securities and Exchange Commission

2:45 pm End of Conference

A G E N D A • F R I D AY, M A R C H 9 D AY 2

This conference is approved for NRS Investment Adviser Certified Compliance Professionalssm (IACCPsm) continuing education credits.

Conference hours will also be eligible for CLE credit in certain states. For more information, please contact Lisa Gillette at [email protected] or (202) 293-4222.

CONTINUING EDUCATION CREDIT

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MARCH 8-9, 2012 11

CANCELLATION/SUBSTITUTION POLICYCancellations must be received by IAA in writing. Written cancellations received by January 31, 2012 will receive a refund, less a $200 administrative fee. No refunds will be given for cancellations made after January 31, 2012. No refunds will be given for “no shows.” You may send a substitute in lieu of the registered person. You may send a written cancellation by mail to IAA, 1050 17th St. NW, Suite 725, Washington, DC 20036; via email to [email protected]; or by fax to (202) 293-4223.

AIR TRAVELIAA has made arrangements with American Airlines for a 6% discount on air travel reservations made online. Simply go to www.AA.com, choose “More Flight Options,” and enter this promotion code in the appropriate box: 1332BF

EXHIBITOR OPPORTUNITIESExhibitor opportunities are available. For more information, please contact Lisa Gillette at [email protected].

CRYSTAL GATEWAY MARRIOTT – Washington, DC Metro Area 1700 Jefferson Davis HighwayArlington, Virginia 22202Phone: (703) 920-3230Fax: (703) 271-5212

Hotel Location: The hotel is located one mile from Reagan Washington National Airport. Transportation from Reagan National Airport:Shuttle: A complimentary hotel shuttle is available during certain hours.Taxi Fare: Estimated $7.00 one wayMetro: Exit Crystal City Station

Overnight Accommodations: A block of rooms has been reserved at the Crystal Gateway Marriott at a special rate of $214 plus tax per night. You are responsible for making your own hotel arrangements. Book early as rooms are limited. You may place a reservation by contacting a hotel reservation agent at (800) 228-9290 or (703) 920-3230. Please mention that you will be attending the IAA Investment Adviser Compliance Conference. You may also visit the IAA web site for the special hotel reservation link. Room reservations must be made by February 10, 2012 to receive the special rate.

REGISTRATION INFORMATION

Registration is available on the IAA’s web site in the “Events” section

Deadline Dates Regular IAA Member Price Fee*

Best Value $1,300 $1,000 Register before December 30, 2011

Early Bird Rate $1,400 $1,150 Register between Dec. 31, 2011 - Jan. 27, 2012

Regular Rate $1,500 $1,250 Register on or after Jan. 28, 2012

REGISTRATION FEES

*IAA Members will automatically receive a discount upon registering. If you have any registration difficulties please contact the IAA at [email protected]. For all other event-related questions, please contact IAA Director of Meetings & Events Lisa Gillette at (307) 733-3332 (direct), (202) 293-4222 (IAA office), or [email protected].

CONFERENCE LOCATION AND HOTEL RESERVATION INFORMATION

u

EXTENDEDDEADLINE!

EXTENDEDDEADLINE!

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IAA INVESTMENT ADVISERCOMPLIANCE CONFERENCE

March 8-9, 2012Crystal Gateway Marriott • Arlington, Virginia(Washington, DC Metro Area)

Topics will include:• Form ADV Part 1 and Part 2 • Whistleblower Rule • Social Media• CCO Liability• SEC Exams

Who Should Attend?• Chief Compliance Officers • General Counsel • Compliance Personnel• In-House Counsel and Outside Counsel• Senior Executives • Industry Consultants

SPONSORED BY: SUPPORTED BY:

Advent Software, Inc., a global firm, has provided trusted solutions to the world’s financial professionals since 1983. Firms in more than 60 countries count on Advent technology to run their mission-critical operations. Advent’s software, data, services and tools help financial professionals improve client service and communication, allowing them to grow their business while controlling operational risk and costs.

Fidelity Institutional Wealth Services is a leading provider of trading, custody and brokerage services to Registered Investment Advisors, Trust Institutions and Third Party Administrators. The company is able to leverage access to a comprehensive set of products and services, innovative investment tools and research, an integrated brokerage and trust platform and dedicated client service. www.fiws.fidelity.com

The Investment Adviser Association is an international non-profit association based in Washington, DC, that represents the interests of SEC-registered investment advisory firms. Founded in 1937, the IAA’s membership consists of more than 500 SEC-registered investment adviser firms that collectively manage in excess of $10 trillion for a variety of institutional and individual clients. For more information, please visit: www.investmentadviser.org

• Enforcement Issues• Pay to Play• ERISA• Code of Ethics• Annual Review