ACA Compliance Group E-Coffeehouse

Investment Advisers

ACA webcast attendee — Wed, 03 Mar 2010 20:08:56 GMT

At the end of the presentation, you were discussing Investment Advisers, could you finish your thought?

Forum: Anti-Money Laundering

Ways to Monitor AML

ACA webcast attendee — Wed, 03 Mar 2010 20:06:34 GMT

What is the best way to monitor AML when you have a transfer of ownership?

Forum: Anti-Money Laundering

PE Firms

ACA webcast attendee — Wed, 03 Mar 2010 20:04:51 GMT

To what extent is this relevant to PE firms?

Forum: Anti-Money Laundering

AML Requirements

ACA webcast attendee — Wed, 03 Mar 2010 20:03:32 GMT

What AML requirements exist for a firm which is a registered investment adviser and NOT a registered broker dealer or affiliated with a bank? Assume further that the adviser deals primarily with institutional clients and not "retail" investors.

Forum: Anti-Money Laundering

US AML Laws

ACA webcast attendee — Wed, 03 Mar 2010 20:01:36 GMT

Aside from the criminal statutes, what US AML laws or rules apply to an SEC-registered investment adviser that is NOT also an SEC-registered broker dealer?

Forum: Anti-Money Laundering

MA Violation

ACA webcast attendee — Thur, 18 Feb 2010 21:19:57 GMT

What is an "incident" for a MA violation? If I have a computer that is lost with 100 MA resident's info on it, is that 1 incident or 100 and thus I could be fined $50kx100?

Forum: Privacy Safeguards

Red Flags Rule

ACA webcast attendee — Thur, 18 Feb 2010 21:19:00 GMT

Is it clear that the Red Flags Rule is applicable to unregistered funds?

Forum: Privacy Safeguards

Non-Public Personal Information

ACA webcast attendee — Thur, 18 Feb 2010 21:18:20 GMT

Under the current version of Reg. S-P, are firms required to offer an opt out to clients that would prevent Advisers leaving the firm from taking client information, even if it is not non-public personal information?

Forum: Privacy Safeguards

Hedge Funds & Unregistered Advisers

ACA webcast attendee — Thur, 18 Feb 2010 21:17:33 GMT

Are hedge funds and unregistered advisers subject to the FTC privacy rules rather than Reg S-P? Is there any significant difference?

Forum: Privacy Safeguards

Standard in S-P

ACA webcast attendee — Thur, 18 Feb 2010 21:16:45 GMT

Is Mass the new standard in S-P? We are trying to decide if it's worth the extra policy/procedure changes for a small amount of Mass clients/revenue if this is the S-P exception not become the new "norm".

Forum: Privacy Safeguards

WISP

ACA webcast attendee — Thur, 18 Feb 2010 21:15:44 GMT

If we have a company safeguarding policy that addresses the requirements of WISP, is that sufficient?

Forum: Privacy Safeguards

Personal Information

ACA webcast attendee — Thur, 18 Feb 2010 21:14:58 GMT

The current slide only applies to vendors who have access to "personal information", correct? Or is it all service providers?

Forum: Privacy Safeguards

Monitoring/Enforcement

ACA webcast attendee — Thur, 18 Feb 2010 21:14:18 GMT

Who provides monitoring/enforcement? Is it MA regulators or the SEC? We are not in MA - would the SEC bring this issue up in an audit?

Forum: Privacy Safeguards

Locking an Office

ACA webcast attendee — Thur, 18 Feb 2010 21:13:19 GMT

Is locking an office enough security, or would we need to lock file cabinets within the office. (For instance, our cleaning service provider has access to locked offices, but not file cabinets.)

Forum: Privacy Safeguards

Institutional Clients

ACA webcast attendee — Thur, 18 Feb 2010 21:11:45 GMT

Does the Mass. law cover institutional clients?

Forum: Privacy Safeguards