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 | 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 | Apr 6, 2023 | Advertising, Best Execution, Books and Records, Chief Compliance Officer, Client Relationship Summary, Code of Ethics, compliance deficiencies, Conflicts of Interest, Duty of Care, Examination Priorities, Fiduciary Duty, Form U4, Investment Adviser Code of Ethics, Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Press Releases, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), RIA Compliance, RIA Compliance Policies, Safeguards Rule, SEC Investment Adviser Compliance, Social Media, Social Media White Paper, Solicitation, Standards of Conduct, State Investment Adviser Compliance
On March 27, 2023, the SEC’s Division of Examinations (Division) published a Risk Alert that will be of great interest to newly-registered investment advisers. The observations will also be invaluable to investment advisers that have been in business for some years....
by Ara Jabrayan | Aug 22, 2019 | ADV Part 2B, Conflicts of Interest, Form ADV, Form U4, Investment Adviser Representative, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, State Investment Adviser Compliance
Registered Investment Advisers (RIAs) owe a duty to supervise persons associated with the firm with respect to activities performed on their behalf. In recent deficiencies letters, RIAs have been criticized for failing to adequately supervise their supervised persons,...
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