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 | 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...
by Ara Jabrayan | Aug 22, 2016 | Code of Ethics, Fiduciary Duty, Investment Adviser Code of Ethics, RIA Compliance, SEC Investment Adviser Compliance, SEC Rules, State Investment Adviser Compliance
Client complaints can negatively impact Registered Investment Advisers (RIAs) for years to come. Examiners expect an RIA to enact policies and procedures detailing how the firm will address complaints. These policies and procedures should demonstrate that the adviser...
by Ara Jabrayan | Jun 21, 2016 | Code of Ethics, Fiduciary Duty, RIA Compliance Polciies, SEC Investment Adviser Compliance, SEC Rules, State Investment Adviser Compliance
In the adopting release to Rule 206(4)-7 under the Advisers Act (commonly known as the Compliance Rule) the SEC listed certain issues that should be addressed by an adviser’s policies and procedures. Among these issues, the SEC expressed its belief that Registered...
by Ara Jabrayan | Mar 21, 2016 | RIA Compliance, RIA Compliance Polciies, SEC Investment Adviser Compliance, SEC Rules, State Investment Adviser Compliance
Rule 204-2 under the Investment Advisers Act identifies the books and records that a Registered Investment Adviser (“RIA”) is required to create and retain. Pursuant to the SEC rule and similar state rules, books and records must be maintained and preserved in an...
Recent Comments