by Ara Jabrayan | Sep 28, 2023 | Advertising, compliance deficiencies, Compliance Violations, Deficiencies, Division of Enforcement, Hypothetical Performance, Investment Adviser Representative, Marketing Rule, policies and procedures, Private Funds, Registered Investment Advisers (RIAs), Retail Investors, RIA Compliance, RIA Compliance Policies, Safeguards Rule, SEC Investment Adviser Compliance, SEC NEWS, Supervision Initiative
On September 11, 2023, the SEC continued its crackdown on Registered Investment Advisers (RIAs) using hypothetical performance advertising by bringing cases against nine advisers. RIAs that advertise hypothetical performance, or plan to do so, should read these SEC...
by Ara Jabrayan | Sep 28, 2023 | ADV Part 2A, ADV Part 2B, Books and Records, Business Continuity and Disaster Recovery Plans, Chief Compliance Officer, Client Relationship Summary, compliance deficiencies, Cybersecurity, Deficiencies, Examination Priorities, Fee Calculations, Form ADV, FORM CRS/Form ADV Part 3, Hedge Clause, Investment Adviser Representative, North American Securities Administrators Association (NASAA), policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Safeguards Rule, State Investment Adviser Compliance
On September 11, 2023, the North American Securities Administrators Association (NASAA) released examination statistics that should serve as a wake-up call for state-registered investment advisers. A series of coordinated examinations of Registered Investment Advisers...
by Ara Jabrayan | Apr 6, 2023 | Advertising, Best Execution, Books and Records, Chief Compliance Officer, Client Relationship Summary, Code of Ethics, compliance deficiencies, Conflicts of Interest, Duty of Care, Examination Priorities, Fiduciary Duty, Form U4, Investment Adviser Code of Ethics, Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Press Releases, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), RIA Compliance, RIA Compliance Policies, Safeguards Rule, SEC Investment Adviser Compliance, Social Media, Social Media White Paper, Solicitation, Standards of Conduct, State Investment Adviser Compliance
On March 27, 2023, the SEC’s Division of Examinations (Division) published a Risk Alert that will be of great interest to newly-registered investment advisers. The observations will also be invaluable to investment advisers that have been in business for some years....
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 | Sep 28, 2021 | Cybersecurity, Investment Adviser Representative, Investment Advisers Act, Registered Investment Advisers (RIAs), Regulation S-P, RIA Compliance, RIA Compliance Policies, Safeguards Rule, SEC Cybersecurity, Uncategorized
Rule 30(a) of Regulation S-P, better known as the Safeguards Rule, requires firms to adopt written policies and procedures to address the administrative, technical, and physical safeguards that are necessary to protect customer records and information. On August 30,...
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