SEC Sanctions RIA and its CEO for Failing to Supervise and Unreasonably Delegating Supervisory Responsibilities

A recent enforcement action has significant implications for Registered Investment Advisers (RIAs), especially for those with multiple Investment Adviser Representatives (IARs) and offices. The case illustrates the SEC’s expectations of firms related to their...

2023 Compliance Roundup Shows RIAs How to Steer Clear of Problems

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,...

RIA’s Hypothetical Performance Ads Cause Real Life Compliance Problems

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...

Off-Channel Communications Will Lead to Record-keeping Violations

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...