SEC Sanctions RIA and its CEO for Failing to Supervise and Unreasonably Delegating Supervisory Responsibilities

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...

SEC’s 2025 Examination Priorities Are a High Priority for RIAs, IARs, and CCOs

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...

SEC Nails 16 Firms for Widespread Recordkeeping Failures Involving Off-Channel Communications

On February 9, 2024, the SEC ordered sixteen firms to pay more than a combined $81 million in civil penalties to settle charges for widespread and long-term recordkeeping failures. The SEC’s investigations identified pervasive and long-term use of unapproved...

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,...

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...