by Ara Jabrayan | Aug 22, 2019 | Conflicts of Interest, Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), Registered Investment Advisers (RIAs), RIA Compliance Policies, SEC Investment Adviser Compliance, Supervision Initiative
On July 23, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert, which discussed its observations from examining firms that currently employ or previously employed supervised persons with a history of disciplinary...
by Ara Jabrayan | Aug 22, 2019 | Client Relationship Summary, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance
On June 5, 2019, the SEC voted to adopt the Form CRS Relationship Summary and Regulation Best Interest, also known as Reg BI. On the same day, the Commission issued two interpretations of the Investment Advisers Act of 1940. In its press release, the SEC stated that...
by Ara Jabrayan | Aug 22, 2019 | Examination Priorities, Registered Investment Advisers (RIAs), RIA Compliance, SEC Investment Adviser Compliance, State Investment Adviser Compliance
Investment adviser routine examination programs and types of exams vary by state. Some are conducted online; some are conducted offsite; and, some are conducted onsite. The SEC conducts various types of routine examinations ranging from limited-scope, remote...
by Ara Jabrayan | Aug 22, 2019 | Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, State Investment Adviser Compliance
In a recent regulatory newsletter to registered investment advisers (RIAs), the Colorado Division of Securities (the Division) provided guidance to RIAs that offer ongoing financial planning services under a fixed or flat retainer fee. The Division reminded RIAs that...
by Ara Jabrayan | Aug 22, 2019 | Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), Regulation S-P, RIA Compliance, RIA Compliance Policies, SEC Cybersecurity, SEC Investment Adviser Compliance, State Investment Adviser Compliance
On April 16, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert dealing with Regulation S-P, which is the Commission’s primary rule governing privacy notices and the safeguarding policies of Registered...
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