Fiduciary Duty Goes Well Beyond Share Class Selection
Investment advisers may have noticed the SEC’s recent Share Class Selection Disclosure Initiative and thought they had nothing to learn from the 79 enforcement actions. The reality is that even investment advisers who are not affiliated with a broker-dealer can...RIAs Breach Their Fiduciary Duty with Improper Share Class Selection
On April 6, 2018, the SEC ordered three Registered Investment Advisers (RIAs) to pay $12 million to clients harmed by the firms’ breach of their fiduciary obligations. The RIAs had generated millions of dollars in improper fees by selecting higher-cost mutual...New SEC Risk Alert Identifies Most Frequent Advertising Rule Compliance Issues
On September 14, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert, which revealed the most frequent advertising rule compliance issues identified in OCIE examinations of Registered Investment Advisers (“RIAs”). OCIE’s...Upcoming Form ADV Changes
As you know, the Securities and Exchange Commission (“SEC”) has adopted amendments to Form ADV Part 1A that will go into effect on October 1, 2017. The expanded Form ADV is part of a new rulemaking effort outlined in SEC Release IA-4509. The updated Form ADV will...The Five Most Frequent Compliance Topics Identified During RIA Exams
The SEC’s Office of Compliance Inspections and Examinations (OCIE) publishes a list of the five compliance topics most frequently identified in deficiency letters sent to SEC-registered investment advisers.
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