by Ara Jabrayan | Mar 6, 2025 | Code of Ethics, Conflicts of Interest, Disclosure, Fiduciary Duty, Fines, Investment Adviser Code of Ethics, Investment Adviser Representative, Liability, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Rules, Securities Exchange Act
On January 14, 2025, three Investment Adviser Representatives (IARs) settled charges brought by the SEC for acting as unregistered brokers. “This case highlights yet another way the StraightPath Funds were marketed and reflects that being associated with a registered...
by Ara Jabrayan | Feb 13, 2025 | Algorithm, Artificial Intelligence, Blockchain, Books and Records, Broker-Dealer, Business Continuity and Disaster Recovery Plans, Chief Compliance Officer, Client Relationship Summary, Compliance Violations, Conflicts of Interest, Crypto-Assets, Cybersecurity, Digital, Division of Examinations, Dually Licensed, Examination Priorities, fees, Fiduciary Duty, FORM CRS/Form ADV Part 3, Investment Adviser Representative, Marketing Rule, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), Regulation S-ID, Regulation S-P, RIA Compliance, RIA Compliance Policies, Standards of Conduct, Uncategorized
On October 21, 2024, the SEC’s Division of Examinations (Division) published its fiscal year priorities for 2025. This annual publication contains information that will be particularly important to Registered Investment Advisers (RIAs), Investment Adviser...
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 | Jan 23, 2024 | Beneficial Ownership Information (BOI) Report, Chief Compliance Officer, Corporate Transparency Act (CTA), Financial Crimes Enforcement Network (FinCEN), Private Funds, Registered Investment Advisers (RIAs), RIA Compliance, U.S. Treasury
The U.S. Treasury has implemented a new beneficial ownership reporting requirement pursuant to the Corporate Transparency Act (CTA). Although SEC-registered investment advisers are not subject to this requirement, state Registered Investment Advisers (RIAs) may be...
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 | Books and Records, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Crypto-Assets, Cybersecurity, Division of Enforcement, Division of Examinations, Hypothetical Performance, Investment Adviser Representative, policies and procedures, Press Releases, Private Funds, Registered Investment Advisers (RIAs), RIA Compliance, SEC NEWS, Social Media
On November 14, 2023, the SEC announced that it had filed 784 total enforcement actions during fiscal year 2023, a three percent increase over fiscal year 2022. Enforcement actions are intended to protect investors and enhance public trust in the securities markets....
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