by Ara Jabrayan | Mar 6, 2025 | Advisory Contract, Code of Ethics, Fiduciary Duty, Investment Adviser Representative, Penalty, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules
On January 17, 2025, the SEC announced that it had settled charges against two Registered Investment Advisers (RIAs), as well as against Merrill Lynch, Pierce, Fenner & Smith Incorporated (Merrill Lynch). Aside from being a broker-dealer, Merrill Lynch is an...
by Ara Jabrayan | Mar 6, 2025 | Code of Ethics, Conflicts of Interest, Disclosure, Fiduciary Duty, Fines, Investment Adviser Code of Ethics, Investment Adviser Representative, Liability, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Rules, Securities Exchange Act
On January 14, 2025, three Investment Adviser Representatives (IARs) settled charges brought by the SEC for acting as unregistered brokers. “This case highlights yet another way the StraightPath Funds were marketed and reflects that being associated with a registered...
by Ara Jabrayan | Mar 6, 2025 | Cherry-Picking, Code of Ethics, Compliance, Compliance Violations, Deceit
On November 25, 2024, the SEC charged the former co-chief investment officer (CIO) of a Registered Investment Adviser (RIA) with fraud. The SEC’s complaint alleged that the CIO engaged in a multi-year cherry-picking scheme, which allocated hundreds of millions of...
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 | 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 23, 2024 | Code of Ethics, Communication, Compliance Violations, Deceit, Fiduciary Duty, RIA Compliance, RIA Compliance Policies, SEC Rules
SEC Charges RIA with Misleading Investors about its Investment Strategy On September 19, 2024, the SEC charged an Idaho-based Registered Investment Adviser (RIA) with making misleading statements, as well as compliance failures, related to the firm’s execution of its...
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