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 | 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 31, 2023 | Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Deficiencies, Division of Enforcement, Division of Examinations, Fee Calculations, Investment Adviser Representative, Investment Advisers Act, Investment Advisers Act - Section 206(2), Investment Advisers Act - Section 206(4), Investment Advisers Act - Section 206(4)-7, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Rules, State Investment Adviser Compliance, Wrap fee, Wrap Program
On August 25, 2023, the SEC accused a dually registered investment adviser/broker-dealer with overcharging thousands of clients. The firm overcharged approximately 10,945 investment advisory accounts by more than $26.8 million in advisory fees. The firm agreed to pay...
by Ara Jabrayan | Aug 30, 2023 | Best Execution, Books and Records, Chief Compliance Officer, Client Relationship Summary, Code of Ethics, Fee Calculations, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, policies and procedures, Private Funds, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules, Standards of Conduct, Wrap fee
On August 23, 2023, the SEC adopted new rules and rule amendments to enhance the regulation of private fund advisers. The SEC also updated Rule 206(4)-7 under the Investment Advisers Act, better known as the Compliance Rule, which applies to all Registered Investment...
by Ara Jabrayan | Jul 28, 2023 | 12b-1 Fees, ADV Part 2A, Books and Records, Chief Compliance Officer, Client Relationship Summary, compliance deficiencies, Compliance Violations, Division of Enforcement, Division of Examinations, Duty of Care, Examination Priorities, Fee Calculations, Fiduciary Duty, Form ADV, Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules, State Investment Adviser Compliance, Wrap fee, Wrap Program
RIA Compliance Group has observed that SEC and state examiners are scrutinizing advisory firms’ fee arrangements and disclosures. Registered Investment Advisers (RIAs) must ensure that they have fully disclosed all of their fees in Form ADV including, but not limited...
by Ara Jabrayan | Jan 7, 2022 | Division of Examinations, Fee Calculations, policies and procedures
On November 10, 2021, the SEC’s Division of Examinations (Division) published a Risk Alert containing examiners’ observations regarding investment advisers’ fee calculations. To arrive at these observations, examiners conducted approximately 130 examinations of...
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