A chief compliance officer (“CCO”) for a registered investment adviser (“RIA”) found himself barred from any compliance or supervisory role in the future because he willfully refused to fix a
Continue Reading CCOs Acting Like Ostriches Will Earn You an SEC Bar
We are regularly approached by both our RIA (and BD too) clients, who inquire, usually around election time, how they should make political contributions. Our advice is usually do not
Continue Reading Political Contributions Result in RIA Fines
In rapid succession, the SEC has issued warnings and announced sanctions against registered investment advisers for fee and expense practices, false statements regarding assets under management, and misleading performance data.
Continue Reading The SEC’s Scare Tactics May Work on Advisers
The SEC recently announced an enforcement initiative that will target retail investor harm. The agency’s task force will use data analytics to find widespread problems regarding fee disclosures and unsuitable
Continue Reading So The SEC Is Now Focused On Retail Investors
Over the last several months, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has been conducting a “sweep examination” of over 70 broker-dealers and investment advisers to assess
Continue Reading Cybersecurity Insights from the SEC
The SEC recently issued an alert for investment advisors regarding cybersecurity. Here is a link to a story on the alert. Are you doing enough to fight this risk? If
Continue Reading Cybersecurity — What are you doing
The SEC recently issued regulatory guidance for robo-advisors. This guidance focuses on what robo-advisors must do to meet their disclosure obligations.
Among other things, the SEC has recommended robust disclosures
Continue Reading What Do The SEC and Robo-Advisors Have In Common
The SEC recently released its findings relating to exams of investment advisers. https://www.sec.gov/ocie/Article/risk-alert-5-most-frequent-ia-compliance-topics.pdf.
In particular, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) found weak compliance programs; insufficient or
Continue Reading SEC’s Exam Deficiencies
According to Bloomberg, Trump plans to order a review of Dodd-Frank, with an eye to significantly scale back the regulations. Trump also plans to do away with the “fiduciary
Continue Reading Trump Sets Plan In Motion To Dismantle Dodd-Frank
In the hectic world of financial services, registered representatives and investment adviser representatives are always looking to increase their assets under management. At what cost? Are there situations where you
Continue Reading When just saying “no” is a good thing