by Ara Jabrayan | Feb 13, 2025 | Audit, Books and Records, Chief Compliance Officer, Code of Ethics, Communication, compliance deficiencies, Compliance Violations, Conflicts of Interest, Criminal, Deficiencies, Digital, Division of Examinations, Dually Licensed, Duty of Care, Electronic Communications Archiving Service, Examination Priorities, Fiduciary Duty, Fines, Form U4, Investment Adviser Code of Ethics, Investment Adviser Representative, Liability, Penalty, policies and procedures, Prison, Recordkeeping, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Risk, Standards of Conduct, State Investment Adviser Compliance, Supervision Initiative
A recent enforcement action has significant implications for Registered Investment Advisers (RIAs), especially for those with multiple Investment Adviser Representatives (IARs) and offices. The case illustrates the SEC’s expectations of firms related to their...
by Ara Jabrayan | Feb 13, 2025 | Algorithm, Artificial Intelligence, Blockchain, Books and Records, Broker-Dealer, Business Continuity and Disaster Recovery Plans, Chief Compliance Officer, Client Relationship Summary, Compliance Violations, Conflicts of Interest, Crypto-Assets, Cybersecurity, Digital, Division of Examinations, Dually Licensed, Examination Priorities, fees, Fiduciary Duty, FORM CRS/Form ADV Part 3, Investment Adviser Representative, Marketing Rule, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), Regulation S-ID, Regulation S-P, RIA Compliance, RIA Compliance Policies, Standards of Conduct, Uncategorized
On October 21, 2024, the SEC’s Division of Examinations (Division) published its fiscal year priorities for 2025. This annual publication contains information that will be particularly important to Registered Investment Advisers (RIAs), Investment Adviser...
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 6, 2024 | Advisory Contract, Audit, Books and Records, Chief Compliance Officer, Compliance Violations, Custody Rule, Deceit, Deficiencies, Duty of Care, Fiduciary Duty, Fines, Hedge Clause, Investment Adviser Representative, Investment Advisers Act - Section 206(4), Liability, Penalty, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), Retail Investors, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS
On September 3, 2024, the SEC announced that it had settled charges against a Registered Investment Adviser (RIA) that failed to comply with requirements pertaining to the safekeeping of client assets. The SEC also alleged that the RIA used impermissible liability...
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 | Apr 3, 2024 | ADV Part 2A, Books and Records, Cherry-Picking, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Deficiencies, Division of Enforcement, Division of Examinations, Fiduciary Duty, Form ADV, Investment Adviser Representative, policies and procedures, Recordkeeping, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, Standards of Conduct
SEC Renders Judgment on RIA with Compliance Problems On February 16, 2024, the SEC obtained a final judgment against a Registered Investment Adviser (RIA) based in Dallas, Texas. The RIA was previously charged with making false and misleading statements in its Form...
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