by Ara Jabrayan | Jan 22, 2024 | "Off-Channel" Communications, 13F, ADV Part 2B, Advertising, Best Execution, Books and Records, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Conflicts of Interest, Custody Rule, Cybersecurity, Deficiencies, Division of Examinations, Duty of Care, Examination Priorities, Fee Calculations, Fiduciary Duty, Form ADV, FORM CRS/Form ADV Part 3, Form U4, Hypothetical Performance, Investment Adviser Representative, Investment Advisers Act, Marketing Rule, policies and procedures, Private Funds, Recordkeeping, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), RIA Compliance, RIA Compliance Policies, Risk, SEC Investment Adviser Compliance, SEC NEWS, Suitability, Whistleblower, Wrap fee, Wrap Program
It has been a busy year for the SEC from a compliance perspective. You should think about these compliance events as you conduct your annual review of your firm’s policies and procedures. An adviser’s policies and procedures should reflect the firm’s business model,...
by Ara Jabrayan | Sep 28, 2023 | 13F, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Division of Enforcement, policies and procedures, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS, Securities Exchange Act, State Investment Adviser Compliance
On September 13, 2023, the SEC brought an enforcement action against a Registered Investment Adviser (RIA) with investment discretion over more than $100 million of reportable securities. The RIA, which has offices in New York, New York, and West Palm Beach, Florida,...
by Ara Jabrayan | Jul 24, 2023 | 13F, Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Division of Enforcement, Division of Examinations, Examination Priorities, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules, State Investment Adviser Compliance, Voting, Voting proxies
On November 2, 2022, the SEC adopted amendments to Form N-PX in order to fulfill one of the remaining mandates established by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Among other changes triggered by the amendments, institutional investment...
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