by Ara Jabrayan | Jan 22, 2024 | "Off-Channel" Communications, 13F, ADV Part 2B, Advertising, Best Execution, Books and Records, Chief Compliance Officer, compliance deficiencies, Compliance Violations, Conflicts of Interest, Custody Rule, Cybersecurity, Deficiencies, Division of Examinations, Duty of Care, Examination Priorities, Fee Calculations, Fiduciary Duty, Form ADV, FORM CRS/Form ADV Part 3, Form U4, Hypothetical Performance, Investment Adviser Representative, Investment Advisers Act, Marketing Rule, policies and procedures, Private Funds, Recordkeeping, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), RIA Compliance, RIA Compliance Policies, Risk, SEC Investment Adviser Compliance, SEC NEWS, Suitability, Whistleblower, Wrap fee, Wrap Program
It has been a busy year for the SEC from a compliance perspective. You should think about these compliance events as you conduct your annual review of your firm’s policies and procedures. An adviser’s policies and procedures should reflect the firm’s business model,...
by Ara Jabrayan | Aug 31, 2023 | Books and Records, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Deficiencies, Division of Enforcement, Division of Examinations, Fee Calculations, Investment Adviser Representative, Investment Advisers Act, Investment Advisers Act - Section 206(2), Investment Advisers Act - Section 206(4), Investment Advisers Act - Section 206(4)-7, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Rules, State Investment Adviser Compliance, Wrap fee, Wrap Program
On August 25, 2023, the SEC accused a dually registered investment adviser/broker-dealer with overcharging thousands of clients. The firm overcharged approximately 10,945 investment advisory accounts by more than $26.8 million in advisory fees. The firm agreed to pay...
by Ara Jabrayan | Jul 28, 2023 | 12b-1 Fees, ADV Part 2A, Books and Records, Chief Compliance Officer, Client Relationship Summary, compliance deficiencies, Compliance Violations, Division of Enforcement, Division of Examinations, Duty of Care, Examination Priorities, Fee Calculations, Fiduciary Duty, Form ADV, Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules, State Investment Adviser Compliance, Wrap fee, Wrap Program
RIA Compliance Group has observed that SEC and state examiners are scrutinizing advisory firms’ fee arrangements and disclosures. Registered Investment Advisers (RIAs) must ensure that they have fully disclosed all of their fees in Form ADV including, but not limited...
by Ara Jabrayan | May 13, 2022 | 12b-1 Fees, Best Execution, Books and Records, Conflicts of Interest, Duty of Care, Fiduciary Duty, Investment Adviser Representative, Investment Advisers Act, Investment Advisers Act - Section 206(2), Investment Advisers Act - Section 206(4), Investment Advisers Act - Section 206(4)-7, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, Share Class Selection, Wrap Program
On April 27, 2022, the SEC announced that it settled charges against a Registered Investment Adviser (RIA) in Downers Grove, Illinois. The SEC alleged that the RIA breached its fiduciary duty to advisory clients by failing to: Fully disclose its conflicts of interest;...
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