by Ara Jabrayan | Apr 8, 2024 | Uncategorized
Although the case involved broker-dealers and not a Registered Investment Adviser (RIA), a recent FINRA enforcement action underscores the importance of implementing and enforcing supervisory systems, including written supervisory procedures (WSPs), to ensure...
by Ara Jabrayan | Jan 24, 2022 | ADV Part 2A, compliance deficiencies, Fiduciary Duty, Registered Investment Advisers (RIAs), Uncategorized
On January 11, 2022, a Registered Investment Adviser (RIA) in Rockaway, New Jersey, consented to the entry of an SEC order that sanctioned the firm for several compliance deficiencies. The RIA also agreed to be censured and to cease-and-desist from engaging in the...
by Ara Jabrayan | Jan 18, 2022 | SEC NEWS, SEC Rules, Securities Exchange Act, Supervision Initiative, Uncategorized
On December 17, 2021, the SEC announced charges against J.P. Morgan Securities LLC (JP Morgan), a broker-dealer subsidiary of JPMorgan Chase & Co. The SEC alleged that the broker-dealer failed to maintain and preserve certain written communications. JP Morgan...
by Ara Jabrayan | Jan 7, 2022 | Division of Examinations, Uncategorized
On September 20, 2021, the North American Securities Administrators Association (NASAA) announced its findings from a series of 1,206 coordinated examinations of state-registered investment advisers. NASAA found that nearly 59 percent of the investment advisers did...
by Ara Jabrayan | Jan 7, 2022 | Uncategorized
On September 29, 2021, the North American Securities Administrators Association (NASAA) published its annual enforcement report. According to the report, state securities regulators conducted an increasing number of investigations and enforcement actions related to...
by Ara Jabrayan | Jan 6, 2022 | Conflicts of Interest, Registered Investment Advisers (RIAs), RIA Compliance, Uncategorized
As you all know, over the last few years, many custodial broker-dealers such as Schwab and TD Ameritrade have reduced their trading commissions to zero on U.S. equities, most ETFs, and most Class A shares of mutual funds. Historically, many custodial broker-dealers...
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