by Ara Jabrayan | Apr 3, 2024 | ADV Part 2A, Books and Records, Cherry-Picking, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Deficiencies, Division of Enforcement, Division of Examinations, Fiduciary Duty, Form ADV, Investment Adviser Representative, policies and procedures, Recordkeeping, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, Standards of Conduct
SEC Renders Judgment on RIA with Compliance Problems On February 16, 2024, the SEC obtained a final judgment against a Registered Investment Adviser (RIA) based in Dallas, Texas. The RIA was previously charged with making false and misleading statements in its Form...
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...
by Ara Jabrayan | Sep 28, 2023 | Books and Records, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Custody Rule, Deficiencies, Division of Enforcement, Form ADV, Investment Adviser Representative, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC NEWS, SEC Rules
On September 5, 2023, the SEC announced charges against five Registered Investment Advisers (RIAs) that failed to comply with requirements designed to safeguard clients’ assets. Three of the firms were also charged with failing to update their disclosure of audits of...
by Ara Jabrayan | Aug 30, 2023 | Account Recommendations, Advertising, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Conflicts of Interest, Division of Enforcement, Division of Examinations, Emerging Technologies, Examination Priorities, Form ADV, Investment Adviser Code of Ethics, Investment Adviser Representative, Marketing Rule, policies and procedures, Press Releases, Registered Investment Advisers (RIAs), Retail Investors, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS, SEC Rules, Social Media, Social Media White Paper, Solicitation, Standards of Conduct, State Investment Adviser Compliance
Although the Cash Solicitation Rule was incorporated in part in the Marketing Rule, there are lessons to be learned from a recent enforcement action. On August 22, 2023, the SEC settled charges against a Registered Investment Adviser (RIA) based in Washington, D.C....
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