by Ara Jabrayan | Sep 20, 2017 | Code of Ethics, Division of Investment Management News, Fiduciary Duty, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, State Investment Adviser Compliance
On September 14, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert, which revealed the most frequent advertising rule compliance issues identified in OCIE examinations of Registered Investment Advisers (“RIAs”). OCIE’s...
by Ara Jabrayan | Sep 20, 2017 | Fiduciary Duty, Form ADV, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, State Investment Adviser Compliance
As you know, the Securities and Exchange Commission (“SEC”) has adopted amendments to Form ADV Part 1A that will go into effect on October 1, 2017. The expanded Form ADV is part of a new rulemaking effort outlined in SEC Release IA-4509. The updated Form ADV will...
by Ara Jabrayan | Feb 21, 2017 | Division of Investment Management News, Fiduciary Duty, Form ADV, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance
On February 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published a list of the five compliance topics most frequently identified in deficiency letters sent to SEC-registered investment advisers. After reviewing more than 1,000...
by Ara Jabrayan | Jan 20, 2017 | Code of Ethics, Division of Investment Management News, Fiduciary Duty, Investment Adviser Code of Ethics, Press Releases, RIA Compliance, RIA Compliance Policies, SEC Cybersecurity, SEC Investment Adviser Compliance, SEC Rules
Each year, the SEC’s Office of Compliance Inspections and Examinations (OCIE) publishes its priorities, and 2017 is no exception. On January 12, 2017, OCIE announced its examination priorities. Registered Investment Advisers (RIAs) and other financial entities will...
by Ara Jabrayan | Nov 28, 2016 | Code of Ethics, RIA Compliance, RIA Compliance Policies, SEC Rules
The SEC has found that Registered Investment Advisers (“RIAs”) may not realize they have custody. Custody” is defined as “holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them.” When an RIA takes custody of a...
by Ara Jabrayan | Oct 18, 2016 | Code of Ethics, Division of Investment Management News, Fiduciary Duty, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules, State Investment Adviser Compliance
The SEC recently imposed sanctions on a Registered Investment Adviser (RIA) in Lexington, Kentucky, because it failed to conduct the required annual review of the firm’s policies and procedures. The firm also ignored its compliance manual, which stipulated that...
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