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...

SEC’s Division of Examinations Announces Its 2023 Priorities

On February 7, 2023, the SEC’s Division of Examinations announced its 2023 examination priorities. These examination priorities are published annually to provide insights into the SEC’s risk-based approach. The publication also identifies areas that present potential...

SEC Risk Alert Gives Guidance on How RIAs Can Comply with Regulation S-ID

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...

SEC Enforcement Actions Against Firms with Weak Cyber Policies

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,...