by Ara Jabrayan | Sep 6, 2024 | Advisory Contract, Audit, Books and Records, Chief Compliance Officer, Compliance Violations, Custody Rule, Deceit, Deficiencies, Duty of Care, Fiduciary Duty, Fines, Hedge Clause, Investment Adviser Representative, Investment Advisers Act - Section 206(4), Liability, Penalty, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), Retail Investors, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS
On September 3, 2024, the SEC announced that it had settled charges against a Registered Investment Adviser (RIA) that failed to comply with requirements pertaining to the safekeeping of client assets. The SEC also alleged that the RIA used impermissible liability...
by Ara Jabrayan | Sep 5, 2024 | "Off-Channel" Communications, Best Execution, Books and Records, Chief Compliance Officer, Code of Ethics, Communication, compliance deficiencies, Compliance Violations, Conflicts of Interest, Cybersecurity, Deceit, Deficiencies, Division of Enforcement, Division of Examinations, Duty of Care, Electronic Communications Archiving Service, Fiduciary Duty, Fines, FINRA, Fraud, Investment Adviser Code of Ethics, Investment Adviser Representative, Investment Advisers Act, Investment Advisers Act - Section 206(4), policies and procedures, Recordkeeping, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), Restitution, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS
On August 12, 2024, the SEC announced that it had settled charges against a New York-based Registered Investment Adviser (RIA). The SEC ordered the RIA to pay over $6 million and to return funds to clients who were harmed by the firm’s undisclosed conflicts of...
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 | 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 | Feb 15, 2024 | "Off-Channel" Communications, Books and Records, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Deficiencies, Division of Enforcement, Electronic Communications Archiving Service, Examination Priorities, Investment Adviser Representative, policies and procedures, Recordkeeping, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance
On February 9, 2024, the SEC ordered sixteen firms to pay more than a combined $81 million in civil penalties to settle charges for widespread and long-term recordkeeping failures. The SEC’s investigations identified pervasive and long-term use of unapproved...
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,...
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