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 | Books and Records, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Crypto-Assets, Cybersecurity, Division of Enforcement, Division of Examinations, Hypothetical Performance, Investment Adviser Representative, policies and procedures, Press Releases, Private Funds, Registered Investment Advisers (RIAs), RIA Compliance, SEC NEWS, Social Media
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....
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 | Sep 28, 2023 | ADV Part 2A, ADV Part 2B, Books and Records, Business Continuity and Disaster Recovery Plans, Chief Compliance Officer, Client Relationship Summary, compliance deficiencies, Cybersecurity, Deficiencies, Examination Priorities, Fee Calculations, Form ADV, FORM CRS/Form ADV Part 3, Hedge Clause, Investment Adviser Representative, North American Securities Administrators Association (NASAA), policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Safeguards Rule, State Investment Adviser Compliance
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...
by Ara Jabrayan | Aug 29, 2023 | Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Cybersecurity, Deficiencies, Division of Enforcement, Division of Examinations, Dually Licensed, Emerging Technologies, Examination Priorities, Investment Adviser Code of Ethics, Investment Adviser Representative, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Risk, SEC Cybersecurity, SEC Investment Adviser Compliance, SEC Rules, Social Media, Standards of Conduct, State Investment Adviser Compliance
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...
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