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 | Algorithm, Artificial Intelligence, Blockchain, Books and Records, Broker-Dealer, Business Continuity and Disaster Recovery Plans, Chief Compliance Officer, Client Relationship Summary, Compliance Violations, Conflicts of Interest, Crypto-Assets, Cybersecurity, Digital, Division of Examinations, Dually Licensed, Examination Priorities, fees, Fiduciary Duty, FORM CRS/Form ADV Part 3, Investment Adviser Representative, Marketing Rule, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), Regulation S-ID, Regulation S-P, RIA Compliance, RIA Compliance Policies, Standards of Conduct, Uncategorized
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...
by Ara Jabrayan | Feb 15, 2024 | "Off-Channel" Communications, Books and Records, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Deficiencies, Division of Enforcement, Electronic Communications Archiving Service, Examination Priorities, Investment Adviser Representative, policies and procedures, Recordkeeping, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance
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...
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...
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...
Recent Comments