Webinar – Prohibited Exemption Training for Investment Advice Fiduciaries

On December 18, 2020, the U.S. Department of Labor (DOL) published its final prohibited transaction exemption addressing investment advice fiduciaries to Employee Retirement Income Security Act of 1974 (ERISA) plans and individual retirement accounts (IRAs). RIA...

SEC Enforcement Actions Signal Continued Scrutiny of 12b-1 Fees, Revenue Sharing Arrangements, and Wrap Fee Programs

In recent weeks, the SEC has continued to bring enforcement actions against Registered Investment Advisers (RIAs) that breached their fiduciary duty to advisory clients. These enforcement actions demonstrate the SEC’s concerns about RIAs that breach their fiduciary...

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,...

SEC Charges 21 RIAs for Form CRS Filing and Delivery Failures

On July 26, 2021, the SEC announced that 21 Registered Investment Advisers (RIAs) settled charges alleging that they failed to file and deliver their client relationship summaries, known as Form CRS, in a timely manner. Form CRS is also frequently referred to as Form...

SEC Releases Findings from its Wrap Fee Initiative Examinations

Wrap fee programs have been on the SEC’s radar for quite a while. When the SEC published its annual examination priorities in 2017, 2018, and 2019, wrap fee programs were mentioned as putting investors at risk. On July 21, 2021, the SEC’s Division of Examinations...