Registration Requirements for Zero De Minimis States

This year alone, the Texas State Securities Board has fined 4 Registered Investments Advisers (RIAs) for providing investment advice to Texas based clients without a proper registration or state notice filing. We would like to remind clients that they need to be...

NASAA 2019 Investment Adviser Coordinated Exam Report

Sample data from state securities examiners is collected every two years and is reported voluntarily to The North American Securities Administrators Association’s (NASAA) Investment Adviser Operations Project Group. At its recent annual meeting, NASAA has recently...

Regulatory Examination Data and Document Production Requests

Investment adviser routine examination programs and types of exams vary by state. Some are conducted online; some are conducted offsite; and, some are conducted onsite. The SEC conducts various types of routine examinations ranging from limited-scope, remote...

SEC Issues Risk Alert Dealing with Regulation S-P Privacy Notices & Safeguard Policies

On April 16, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert dealing with Regulation S-P, which is the Commission’s primary rule governing privacy notices and the safeguarding policies of Registered...