SEC Sanctions RIA and its CEO for Failing to Supervise and Unreasonably Delegating Supervisory Responsibilities

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...

2023 Compliance Roundup Shows RIAs How to Steer Clear of Problems

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,...

SEC’s Division of Examinations Risk Alert Regarding Observations from Examinations of Newly-Registered Advisers

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....

Supervision of Investment Adviser Representatives

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,...