by Ara Jabrayan | Mar 11, 2025 | Compliance Violations, Conflicts of Interest, Duty of Care, Fiduciary Duty, Investment Adviser Representative, policies and procedures, Registered Investment Advisers (RIAs), SEC Investment Adviser Compliance, Standards of Conduct, Suitability, Violations
On February 14, 2025, the SEC settled charges against a New York-based Registered Investment Adviser (RIA) and a former Investment Adviser Representative (IAR) of that firm. The RIA and IAR allegedly breached the fiduciary duty they owed to their clients. The RIA and...
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 | 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 | 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...
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