by Ara Jabrayan | Apr 29, 2024 | Code of Ethics, Communication, Compliance Violations, Deceit, Division of Enforcement, Fines, Fraud, Investment Adviser Code of Ethics, Investment Adviser Representative, Investment Advisers Act - Section 206(2), Marketing Rule, RIA Compliance
On April 22, 2024, the SEC resolved an enforcement action against an investment adviser and the firm’s owner based in Fort Lauderdale. The enforcement action demonstrates how important it is for investment advisers and Investment Adviser Representatives to be accurate...
by Ara Jabrayan | Aug 30, 2023 | Advertising, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Conflicts of Interest, Deficiencies, Division of Enforcement, Division of Examinations, Emerging Technologies, Examination Priorities, Investment Adviser Code of Ethics, Investment Adviser Representative, Marketing Rule, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Press Releases, Registered Investment Advisers (RIAs), Retail Investors, RIA Compliance, RIA Compliance Policies, Risk, SEC Investment Adviser Compliance, SEC NEWS, SEC Rules, State Investment Adviser Compliance
On August 21, 2023, the SEC charged a New York-based FinTech investment adviser with using misleading hypothetical performance metrics in the firm’s advertisements. This enforcement action is particularly noteworthy, because it is the first case brought involving...
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 | 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....
by Ara Jabrayan | Aug 29, 2023 | Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Cybersecurity, Deficiencies, Division of Enforcement, Division of Examinations, Dually Licensed, Emerging Technologies, Examination Priorities, Investment Adviser Code of Ethics, Investment Adviser Representative, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Risk, SEC Cybersecurity, SEC Investment Adviser Compliance, SEC Rules, Social Media, Standards of Conduct, State Investment Adviser Compliance
On August 8, 2023, the SEC charged eleven financial services firms, including a dually registered broker-dealer (BD) and Registered Investment Adviser (RIA), with widespread record-keeping violations. The firms acknowledged their wrongdoing and agreed to pay combined...
by Ara Jabrayan | Jul 24, 2023 | 13F, Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Division of Enforcement, Division of Examinations, Examination Priorities, Fiduciary Duty, Investment Adviser Code of Ethics, 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, Voting, Voting proxies
On November 2, 2022, the SEC adopted amendments to Form N-PX in order to fulfill one of the remaining mandates established by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Among other changes triggered by the amendments, institutional investment...
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