by Ara Jabrayan | Jan 10, 2023 | Best Execution, Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Cybersecurity, Deficiencies, Division of Enforcement, Division of Examinations, Duty of Care, Examination Priorities, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, policies and procedures, Press Releases, Registered Investment Advisers (RIAs), Regulation S-ID, RIA Compliance, RIA Compliance Policies, Safeguards Rule, SEC Cybersecurity, SEC Investment Adviser Compliance, SEC NEWS, SEC Rules, Standards of Conduct, Supervision Initiative
On December 5, 2022, the Division of Examinations (Division) published a Risk Alert that reported observations from recent examinations of SEC-registered investment advisers (RIAs) and broker-dealers related to their compliance with Regulation S-ID. The goal of the... by Ara Jabrayan | Jan 10, 2023 | Best Execution, Books and Records, Cherry-Picking, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Conflicts of Interest, Deficiencies, Division of Enforcement, DOL Fiduciary Rule, Duty of Care, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), RIA Compliance, RIA Compliance Policies, Safeguards Rule, SEC Investment Adviser Compliance, SEC NEWS, SEC Rules, SEC Staff Bulletin, Standards of Conduct, Supervision Initiative
On November 15, 2022, the SEC announced its enforcement results for fiscal year 2022. Despite the lingering impact of COVID 19, the SEC filed 760 enforcement actions and recovered a record $6.439 billion in penalties and disgorgement on behalf of investors. The... by Ara Jabrayan | Jan 10, 2023 | Best Execution, Books and Records, Business Continuity and Disaster Recovery Plans, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Conflicts of Interest, Examination Priorities, Fiduciary Duty, Form ADV, FORM CRS/Form ADV Part 3, Investment Adviser Code of Ethics, North American Securities Administrators Association (NASAA), policies and procedures, Press Releases, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Solicitation, Standards of Conduct, State Investment Adviser Compliance
Recently the North American Securities Administrators Association (NASAA) released its annual Enforcement Report. The publication highlighted the investigations and enforcement actions taken by state securities regulators to protect investors and maintain the... by Ara Jabrayan | Oct 19, 2022 | Conflicts of Interest, Fiduciary Duty, Investment Advisers Act, policies and procedures, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Staff Bulletin
On August 3, 2022, the SEC published a Staff Bulletin, which discussed investment advisers’ and broker-dealers’ conflicts of interest. The Staff Bulletin offered guidance on how firms can identify, eliminate, mitigate, and disclose those conflicts of interest. The... by Ara Jabrayan | Jul 20, 2022 | Chief Compliance Officer, Registered Investment Advisers (RIAs), RIA Compliance, SEC Investment Adviser Compliance
For Chief Compliance Officers (CCOs) who worry that they face personal liability for their mistakes, a recent enforcement action should provide some degree of comfort. After the CCO for a Georgia-based Registered Investment Adviser (RIA) was found personally liable by... by Ara Jabrayan | May 13, 2022 | 12b-1 Fees, Best Execution, Books and Records, Conflicts of Interest, Duty of Care, Fiduciary Duty, Investment Adviser Representative, Investment Advisers Act, Investment Advisers Act - Section 206(2), Investment Advisers Act - Section 206(4), Investment Advisers Act - Section 206(4)-7, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, Share Class Selection, Wrap Program
On April 27, 2022, the SEC announced that it settled charges against a Registered Investment Adviser (RIA) in Downers Grove, Illinois. The SEC alleged that the RIA breached its fiduciary duty to advisory clients by failing to: Fully disclose its conflicts of interest;...
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