by Ara Jabrayan | Feb 13, 2025 | Account Recommendations, Advisory Contract, Best Execution, Broker-Dealer, Candidate, Chief Compliance Officer, Code of Ethics, commissions, Communication, Compliance Violations, Deceit, Disgorgement, Dually Licensed, Fee Calculations, fees, Fines, investment management agreement, Penalties, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance Policies, Risk, SEC Investment Adviser Compliance, SEC NEWS, Share Class Selection, Suitability, Violations, Whistleblower, Whistleblower Protection Rule
On September 25, 2024, the SEC charged two firms with ignoring clients’ instructions and exceeding their designated investment limits for over two years. The two firms charged were Merrill Lynch, Pierce, Fenner & Smith Inc. (“Merrill Lynch”), a registered...
by Ara Jabrayan | Sep 5, 2024 | "Off-Channel" Communications, Best Execution, Books and Records, Chief Compliance Officer, Code of Ethics, Communication, compliance deficiencies, Compliance Violations, Conflicts of Interest, Cybersecurity, Deceit, Deficiencies, Division of Enforcement, Division of Examinations, Duty of Care, Electronic Communications Archiving Service, Fiduciary Duty, Fines, FINRA, Fraud, Investment Adviser Code of Ethics, Investment Adviser Representative, Investment Advisers Act, Investment Advisers Act - Section 206(4), policies and procedures, Recordkeeping, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), Restitution, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS
On August 12, 2024, the SEC announced that it had settled charges against a New York-based Registered Investment Adviser (RIA). The SEC ordered the RIA to pay over $6 million and to return funds to clients who were harmed by the firm’s undisclosed conflicts of...
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 | Nov 21, 2023 | Account Recommendations, Best Execution, Books and Records, Business Continuity and Disaster Recovery Plans, Chief Compliance Officer, Compliance Violations, Conflicts of Interest, Cyberattack, Cybersecurity, Division of Enforcement, Division of Examinations, Duty of Care, Examination Priorities, Fiduciary Duty, Form ADV, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Risk, SEC Cybersecurity, SEC Investment Adviser Compliance, SEC NEWS, SEC Rules, Suitability
On October 16, 2023, Registered Investment Advisers (RIAs) and other regulated firms received sooner-than-expected guidance from the SEC when the Commission published its 2024 examination priorities. The SEC previously announced its 2023 examination priorities on...
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 | May 15, 2023 | 12b-1 Fees, Account Recommendations, Best Execution, Chief Compliance Officer, Client Relationship Summary, Code of Ethics, DOL Fiduciary Rule, Duty of Care, ERISA, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, Investment Advisers Act, policies and procedures, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), Retail Investors, RIA Compliance, Risk, Robo-Advisers, SEC Investment Adviser Compliance, SEC Staff Bulletin, Standards of Conduct, State Investment Adviser Compliance, Suitability
On April 20, 2023, the SEC published a staff bulletin in a question-and-answer format to reinforce the standards of conduct owed by broker-dealers and Registered Investment Advisers (RIAs) when they are giving investment advice and making recommendations to retail...
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