2023 Compliance Roundup Shows RIAs How to Steer Clear of Problems

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,...

SEC Enforcement Stats Serve as Warning to RIAs and Other Firms

On November 14, 2023, the SEC announced that it had filed 784 total enforcement actions during fiscal year 2023, a three percent increase over fiscal year 2022. Enforcement actions are intended to protect investors and enhance public trust in the securities markets....

NASAA’s Exam Findings Warn State RIAs About Potential Compliance Pitfalls

On September 11, 2023, the North American Securities Administrators Association (NASAA) released examination statistics that should serve as a wake-up call for state-registered investment advisers. A series of coordinated examinations of Registered Investment Advisers...

Off-Channel Communications Will Lead to Record-keeping Violations

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...

SEC’s Division of Examinations Announces Its 2023 Priorities

On February 7, 2023, the SEC’s Division of Examinations announced its 2023 examination priorities. These examination priorities are published annually to provide insights into the SEC’s risk-based approach. The publication also identifies areas that present potential...