SEC adopts new disclosure and recordkeeping requirements for investment advisers

2017 ◽  
Vol 18 (1) ◽  
pp. 19-24
Author(s):  
Nathan J. Greene
Keyword(s):  
Content Type ◽  
Public Firms ◽  
Record Keeping ◽  
Performance Reporting ◽  
Reporting Requirements ◽  
Retrieval Processes ◽  
New Public ◽  
Client Data ◽  
Disclosure Rules ◽  
Investment Advisers

Purpose To alert investment advisers to changes to be implemented to the Securities and Exchange Commission’s (SEC’s) Form ADV requirements as of October 1, 2017. Form ADV is the SEC’s principal investment adviser registration form. Design/methodology/approach Explains new public disclosure reporting requirements for investment adviser separately managed accounts (SMA) businesses, assesses the new “umbrella registration rules” that will govern how related advisers are treated by Form ADV, outlines key changes to Form ADV on a provision-by-provision basis, summarizes various other technical additions to Form ADV, and examines new performance reporting record-keeping requirements. Findings The Form ADV amendments are significant. Investment advisers should be preparing for compliance ahead of the October 2017 compliance date. Information retrieval processes will need to be reviewed and tested against the new disclosure rules. Firms will want to coordinate with their clients to minimize surprises when client data (albeit on an aggregated basis) is made public. Firms that operate under umbrella registrations should check their eligibility against the new rules. Originality/value Practical and informative guidance from experienced investment adviser attorneys that consolidates the key provisions of which investment advisers should be aware under new SEC disclosure and recordkeeping requirements.

scholarly journals Heritage reporting by the Australian public sector

2019 ◽  
Vol 32 (2) ◽  
pp. 612-631 ◽  
Author(s):  
Peir Peir Woon ◽  
Bikram Chatterjee ◽  
Carolyn J. Cordery
Keyword(s):  
Public Sector ◽  
Financial Reporting ◽  
Public Management ◽  
Information Needs ◽  
New Public Management ◽  
Content Type ◽  
For Profit ◽  
Reporting Requirements ◽  
New Public ◽  
Proposed Model

Purpose The purpose of this paper is to contribute to the future development of heritage reporting in Australia. Public sector reporting of heritage has been a long-standing issue, due to shortcomings in (sector-neutral) for-profit-based financial reporting standards. Australia’s sector-neutral approach does not meet public sector users’ information needs. The authors develop a heritage reporting model to balance community and other stakeholders’ interests and address prior critiques. Design/methodology/approach The paper reviews heritage reporting requirements in Anglo-Western Countries, and analyses commentaries and research publications. It evaluates the existing reporting requirements in the context of new public management (which focusses on information and efficiency) and new public governance (NPG) (focussing on balancing interests and quality). Findings The paper proposes an NPG-based heritage reporting model which includes indicators of performance on the five UNESCO (1972) dimensions and operational guidelines issued by UNESCO (2015). These are identification, presentation, protection, conservation and transmission. The proposed model is consistent with the notion of US SFFAS 29 (the standard for Federal entities). Not all heritage must be capitalised and hence attachment of monetary value, but detailed disclosures are necessary. Research limitations/implications The authors expect the proposed heritage reporting model to better serve users of heritage information compared to the present Australian Accounting Standards Board 116: Property, Plant and Equipment. Originality/value The authors’ proposed model of heritage reporting attempts to answer Carnegie and Wolnizer’s (1995, 1999) six questions, addresses decades of concerns raised in previous literature and provides a new perspective to heritage reporting based on NPG that should better serve users’ needs.

SEC issues proposed investment adviser reporting and disclosure rules

2015 ◽  
Vol 16 (4) ◽  
pp. 23-29 ◽  
Author(s):  
Nathan J. Greene
Keyword(s):  
Securities And Exchange Commission ◽  
Performance Information ◽  
Investment Funds ◽  
Content Type ◽  
Investment Companies ◽  
Reporting Requirements ◽  
The Usa ◽  
Investment Advisers ◽  
Internal Procedures ◽  
Separate Account

Purpose – To explain proposed rules and amendments recently issued by the USA Securities and Exchange Commission (SEC) that would impose more detailed reporting requirements for investment advisers that file Form ADV. A companion article describes the SEC’s proposed registered investment company reporting rules which were issued simultaneously. Design/methodology/approach – Describes the SEC’s reasoning for collecting more detailed data, introduces the proposed separate account reporting requirements for SEC-registered investment advisers, explains proposed amendments to Part 1A of Form ADV, describes a proposed codification of SEC staff positions that provide for so-called “umbrella registrations” by closely related advisory firms, and details two proposed amendments to Advisers Act Rule 204-2, the books and records rule, which would require investment advisers to maintain additional materials related to the calculation and distribution of performance information. Findings – Many questions still remain as to how the final rules will eventually take shape; however, it is evident that investment advisers will be subject to a wider array of reporting requirements. Investment advisors are likely to incur increased costs as a result of the proposed rules and amendments, and production of the reports could necessitate a revamp of their various internal procedures. Also, access to additional and enhanced information will have consequences for investment companies with respect to SEC examinations and enforcement activity. Practical implications – Investment advisers should understand that detailed new regulatory reporting is coming and, more specifically, separately managed account clients of investment advisers should be made aware of the proposed reporting requirements. Originality/value – Practical guidance from experienced investment funds lawyer.

Performance reporting in Ireland: the ongoing gap between rhetoric and reality

2015 ◽  
Vol 28 (1) ◽  
pp. 2-10 ◽  
Author(s):  
Francis McGeough
Keyword(s):  
Performance Indicators ◽  
Public Management ◽  
New Public Management ◽  
Annual Report ◽  
Annual Reports ◽  
Performance Information ◽  
Content Type ◽  
Performance Reporting ◽  
New Public ◽  
Important Means

Purpose – The annual report is an important means of organisational accountability. In recent years, public sector organisations (PSOs) influenced by New Public Management have been expected to publish performance information which will enable the readers of the annual report to assess how the organisation is doing. The purpose of this paper is to examine the level of performance information published by a range of PSOs in Ireland to verify if the increased emphasis on performance reporting was having an impact on actual reporting by PSOs. Design/methodology/approach – The research involved a detailed study of a number of annual reports published by Irish PSOs over two time periods. These organisations had an operational focus and were standalone. Findings – The research finds that Irish PSOs publish a reasonable level of performance indicators but most of these indicators are not compared to a target; the majority of organisations do not publish any targets in their annual report. This makes it very difficult for the reader to assess how the organisation is doing. The level of reporting has not improved since the OECD report of 2008. Originality/value – The research finds that there is a substantial gap between the rhetoric of reform as set out in official government documentation and the reality of reporting by Irish PSOs. This reduces the level of accountability and raises doubts about the performance and effectiveness of Irish PSOs.

SEC proposes rules on adviser business continuity and transition plans

2016 ◽  
Vol 17 (4) ◽  
pp. 65-70 ◽  
Author(s):  
Kay Gordon
Keyword(s):  
Design Methodology ◽  
Business Continuity ◽  
Content Type ◽  
Record Keeping ◽  
Transition Plans ◽  
The Us ◽  
Investment Advisers ◽  
Definition Of ◽  
The Universe ◽  
Practical Implications

Purpose To discuss the requirements and implications of the US Securities and Exchange Commission’s (SEC’s) proposed new Rule 206(4)-4, which would require all SEC-registered investment advisers to adopt and implement written business continuity and transition plans (BCPs) reasonably designed to address operational and other risks related to a significant disruption in the investment adviser’s operations. Design/methodology/approach Explains the proposed rules’ definition of and specific requirements of BCPs, other requirements relating to annual reviews and record-keeping, practical considerations including advisers’ need to update and revise their BCPs, and the SEC’s request for comment on issues including possible additional obligations for certain types of clients, reporting of incidents to the SEC, and filing of BCPs with the SEC. Findings By arguably broadening its approach to the universe of risks that should be addressed in a BCP, the SEC potentially places a higher burden on the advisers to design their BCPs to anticipate all material risks that may become applicable or be responsible for a violation of their fiduciary duties to clients. Practical implications Given the detailed requirements of the Proposed Rules, including as interpreted by the Proposing Release, it is likely that most registered advisers would have to revisit and revise their BCPs if the rules are adopted. Originality/value Practical guidance from experienced securities, fund management, regulatory and compliance lawyer.

A people's palace opens: the new Library of Birmingham

2014 ◽  
Vol 115 (1/2) ◽  
pp. 65-67
Author(s):  
Mike Freeman
Keyword(s):  
Interior Design ◽  
Design Methodology ◽  
Public Library ◽  
Content Type ◽  
Special Collections ◽  
New Public ◽  
Official Opening

Purpose – The purpose of this report is to provide an account of the UK's new public library of Birmingham. Design/methodology/approach – Details the construction, exterior and interior design, contents and location, including special collections, and describes the official opening. Findings – A large public library building which moves away from old conceptions of libraries, accommodating a variety of functions in a striking and accessible building. Originality/value – Provides a description of the new Library of Birmingham, the largest public library in Europe.

OCIE issues risk alert on the most frequently identified advisory fee and expense compliance issues

2018 ◽  
Vol 19 (4) ◽  
pp. 1-3
Author(s):  
Robert Van Grover
Keyword(s):  
Design Methodology ◽  
Best Practice ◽  
Investment Management ◽  
Content Type ◽  
Informed Decisions ◽  
Policies And Procedures ◽  
The Us ◽  
Investment Advisers ◽  
Practical Implications

Purpose To summarize and interpret a Risk Alert issued on April 12, 2018 by the US SEC’s Office of Compliance Inspections and Examinations (OCIE) on the most frequent advisory fee and expense compliance issues identified in recent examinations of investment advisers. Design/methodology/approach Summarizes deficiencies identified by the OCIE staff pertaining to advisory fees and expenses in the following categories: fee billing based on incorrect account valuations, billing fees in advance or with improper frequency, applying incorrect fee rates, omitting rebates and applying discounts incorrectly, disclosure issues involving advisory fees, and adviser expense misallocations. Findings In the Risk Alert, OCIE staff emphasized the importance of disclosures regarding advisory fees and expenses to the ability of clients to make informed decisions, including whether or not to engage or retain an adviser. Practical implications In light of the issues identified in the Risk Alert, advisers should assess the accuracy of disclosures and adequacy of policies and procedures regarding advisory fee billing and expenses. As a matter of best practice, advisers should implement periodic forensic reviews of billing practices to identify and correct issues relating to fee billing and expenses. Originality/value Expert guidance from experienced investment management lawyer.

scholarly journals New public management and budgeting practices in Tanzanian Central Government

2016 ◽  
Vol 6 (4) ◽  
pp. 340-371 ◽  
Author(s):  
Andrew Goddard ◽  
Tausi Ally Mkasiwa
Keyword(s):  
Public Management ◽  
New Public Management ◽  
Central Government ◽  
Successful Implementation ◽  
Donor Funding ◽  
Policy Makers ◽  
Content Type ◽  
Inductive Research ◽  
New Public ◽  
Research Findings

Purpose The purpose of this paper is to investigate the budgeting practices in the Tanzanian Central Government. New budgeting reforms were introduced following exhortations from the bodies such as the UN, the World Bank and the IMF and reflect the new public management (NPM). Design/methodology/approach A grounded theory methodology was used. This methodology is inductive, allowing phenomena to emerge from the participants rather than from prior theory. This ensures both relevance and depth of understanding. Findings The principal research findings from the data concern the central phenomenon of “struggling for conformance”. Tanzanian Central Government adopted innovations in order to ensure donor funding by demonstrating its ability to implement imposed budgetary changes. Organizational actors were committed to these reforms through necessity and struggled to implement them, rather than more overtly resisting them. Research limitations/implications The research is subject to the usual limitations of case study, inductive research. Practical implications This research has several implications for policy-makers of NPM and budgetary reforms. These include the recognition that the establishment of the rules and regulations alone is not adequate for the successful implementation of budgetary and NPM reforms and should involve a comprehensive view of the nature of the internal and external environment. Originality/value There are few empirical papers of NPM accounting practices being implemented in the public sector of developing countries and none at all based in Tanzania. The paper identifies the existence of struggling to conform to reforms rather than resistance identified in prior research.

Mandatory corporate social responsibility in India: reporting reality, issues and way forward

2021 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Pawan Taneja ◽  
Ameeta Jain ◽  
Mahesh Joshi ◽  
Monika Kansal
Keyword(s):  
Corporate Social Responsibility ◽  
Social Responsibility ◽  
Mandatory Reporting ◽  
Content Type ◽  
Csr Reporting ◽  
Reporting Requirements ◽  
Expectation Gap ◽  
The Government ◽  
Corporate Social ◽  
The Impact

Purpose Since 2013, the Indian Companies Act Section 135 has mandated corporate social responsibility (CSR) reporting by Indian central public sector enterprises (CPSEs). CSR reporting is regulated by multiple Government of India ministerial agencies, each requiring different formats and often different data. This study aims to understand the impact of these multiple regulatory bodies on CSR reporting by Indian CPSEs; evaluate the expectation gap between regulators and the regulated; and investigate the compliance burden on CPSEs. Design/methodology/approach An interview-based approach was adopted to evaluate the perspectives of both regulators and regulated CPSEs on the impact of the new regulations on CSR reporting quality. The authors use the lens of institutional theory to analyse the findings. Findings Driven by coercive institutional pressures, CPSEs are overburdened with myriad reporting requirements, which significantly negatively impact CPSEs’ financial and human resources and the quality of CSR activity and reports. It is difficult for CPSEs to assess the actual impact of their CSR activities due to overlapping with activities of the government/other institutions. The perceptions of regulators and the regulated are divergent: the regulators expect CPSEs to select more impactful CSR projects to comply with mandatory reporting requirements. Originality/value The findings of this study emphasise the need for meaningful dialogue between regulators and the regulated to reduce the expectation gap and establish a single regulatory authority that will ensure that the letter and spirit of the law are followed in practice and not just according to a tick-box approach.

A comparative study of formal coaching and mentoring programmes in higher education

2022 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Jenni Jones ◽  
Helen A. Smith
Keyword(s):  
Higher Education ◽  
Undergraduate Students ◽  
Business School ◽  
Best Practice ◽  
Application Process ◽  
Content Type ◽  
Record Keeping ◽  
Practice Recommendations ◽  
Matching Process ◽  
Two Phases

PurposeThe purpose of this paper is to evaluate two coaching and mentoring programmes focused on the ever-increasingly important aim of enhancing the chances of professional level employment for undergraduate students, at two UK universities. In addition, to offer recommendations to enhance coaching and mentoring success within higher education (HE).Design/methodology/approachTwo similar programmes are compared; the first study is a coaching programme delivered in two phases involving over 1,500 students within the business school. The second study is a mentoring programme involving over 250 students over a ten-year period within the business school at a different institution.FindingsThe two programmes have been compared against the key success criteria from the literature, endorsed by coaching and mentoring experts. The results highlight the importance of integrating with other initiatives, senior management commitment, budget, an application process, clear matching process, trained coaches and mentors, induction for both parties, supportive material, ongoing supervision and robust evaluation and record keeping.Research limitations/implicationsThe research focuses on two similar institutions, with comparable student demographics. It would have been useful to dig deeper into the effect of the diverse characteristics of coach/mentor and coachee/mentee on the effectiveness of their relationships. In addition, to test the assumptions and recommendations beyond these two institutions, and to validate the reach and application of these best practice recommendations further afield.Practical implicationsThe results identify a number of best practice recommendations to guide HE institutions when offering coaching and mentoring interventions to support career progression of their students.Originality/valueThere are limited comparison studies between universities with undergraduate career-related coaching and mentoring programmes and limited research offering best practice recommendations for coaching and mentoring programmes in HE. The top ten factors offered here to take away will add value to those thinking of running similar programmes within HE.

scholarly journals Accounting and the post-new public management

2018 ◽  
Vol 32 (1) ◽  
pp. 255-279 ◽  
Author(s):  
Ileana Steccolini
Keyword(s):  
Public Sector ◽  
Public Administration ◽  
Public Management ◽  
New Public Management ◽  
Content Type ◽  
The Public ◽  
Accounting Research ◽  
Societal Relevance ◽  
New Public ◽  
Public Sector Accounting

Purpose The purpose of this paper is to reflect various pathways for public sector accounting and accountability research in a post-new public management (NPM) context. Design/methodology/approach The paper first discusses the relationship between NPM and public sector accounting research. It then explores the possible stimuli that inter-disciplinary accounting scholars may derive from recent public administration studies, public policy and societal trends, highlighting possible ways to extend public sector accounting research and strengthen dialogue with other disciplines. Findings NPM may have represented a golden age, but also a “golden cage,” for the development of public sector accounting research. The paper reflects possible ways out of this golden cage, discussing future avenues for public sector accounting research. In doing so, it highlights the opportunities offered by re-considering the “public” side of accounting research and shifting the attention from the public sector, seen as a context for public sector accounting research, to publicness, as a concept central to such research. Originality/value The paper calls for stronger engagement with contemporary developments in public administration and policy. This could be achieved by looking at how public sector accounting accounts for, but also impacts on, issues of wider societal relevance, such as co-production and hybridization of public services, austerity, crises and wicked problems, the creation and maintenance of public value and democratic participation.

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