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
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The SEC’s Scare Tactics May Work on Advisers
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.
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So The SEC Is Now Focused On Retail Investors
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
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Cybersecurity Insights from the SEC
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
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Cybersecurity — What are you doing
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
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What Do The SEC and Robo-Advisors Have In Common
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
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SEC’s Exam Deficiencies
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
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Trump Sets Plan In Motion To Dismantle Dodd-Frank
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
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A Data Breach! You Better Check The Law Of The States In Which You Have Customers
Consistent with the ongoing guidance/requirements from the SEC and FINRA, all firms must have and enforce data security policies and procedures. Even the best policies and procedures may, however, not
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When just saying “no” is a good thing
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
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