by Ara Jabrayan | Aug 31, 2023 | Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Deficiencies, Division of Enforcement, Division of Examinations, Fee Calculations, Investment Adviser Representative, Investment Advisers Act, Investment Advisers Act - Section 206(2), Investment Advisers Act - Section 206(4), Investment Advisers Act - Section 206(4)-7, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Rules, State Investment Adviser Compliance, Wrap fee, Wrap Program
On August 25, 2023, the SEC accused a dually registered investment adviser/broker-dealer with overcharging thousands of clients. The firm overcharged approximately 10,945 investment advisory accounts by more than $26.8 million in advisory fees. The firm agreed to pay...
by Ara Jabrayan | Aug 30, 2023 | Advertising, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Conflicts of Interest, Deficiencies, Division of Enforcement, Division of Examinations, Emerging Technologies, Examination Priorities, Investment Adviser Code of Ethics, Investment Adviser Representative, Marketing Rule, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Press Releases, Registered Investment Advisers (RIAs), Retail Investors, RIA Compliance, RIA Compliance Policies, Risk, SEC Investment Adviser Compliance, SEC NEWS, SEC Rules, State Investment Adviser Compliance
On August 21, 2023, the SEC charged a New York-based FinTech investment adviser with using misleading hypothetical performance metrics in the firm’s advertisements. This enforcement action is particularly noteworthy, because it is the first case brought involving...
by Ara Jabrayan | Aug 30, 2023 | Best Execution, Books and Records, Chief Compliance Officer, Client Relationship Summary, Code of Ethics, Fee Calculations, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, policies and procedures, Private Funds, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules, Standards of Conduct, Wrap fee
On August 23, 2023, the SEC adopted new rules and rule amendments to enhance the regulation of private fund advisers. The SEC also updated Rule 206(4)-7 under the Investment Advisers Act, better known as the Compliance Rule, which applies to all Registered Investment...
by Ara Jabrayan | Aug 30, 2023 | Account Recommendations, Advertising, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Conflicts of Interest, Division of Enforcement, Division of Examinations, Emerging Technologies, Examination Priorities, Form ADV, Investment Adviser Code of Ethics, Investment Adviser Representative, Marketing Rule, policies and procedures, Press Releases, Registered Investment Advisers (RIAs), Retail Investors, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS, SEC Rules, Social Media, Social Media White Paper, Solicitation, Standards of Conduct, State Investment Adviser Compliance
Although the Cash Solicitation Rule was incorporated in part in the Marketing Rule, there are lessons to be learned from a recent enforcement action. On August 22, 2023, the SEC settled charges against a Registered Investment Adviser (RIA) based in Washington, D.C....
by Ara Jabrayan | Aug 29, 2023 | Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Cybersecurity, Deficiencies, Division of Enforcement, Division of Examinations, Dually Licensed, Emerging Technologies, Examination Priorities, Investment Adviser Code of Ethics, Investment Adviser Representative, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Risk, SEC Cybersecurity, SEC Investment Adviser Compliance, SEC Rules, Social Media, Standards of Conduct, State Investment Adviser Compliance
On August 8, 2023, the SEC charged eleven financial services firms, including a dually registered broker-dealer (BD) and Registered Investment Adviser (RIA), with widespread record-keeping violations. The firms acknowledged their wrongdoing and agreed to pay combined...
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