by Ara Jabrayan | Mar 6, 2025 | Advisory Contract, Code of Ethics, Fiduciary Duty, Investment Adviser Representative, Penalty, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules
On January 17, 2025, the SEC announced that it had settled charges against two Registered Investment Advisers (RIAs), as well as against Merrill Lynch, Pierce, Fenner & Smith Incorporated (Merrill Lynch). Aside from being a broker-dealer, Merrill Lynch is an...
by Ara Jabrayan | Feb 13, 2025 | Account Recommendations, Advisory Contract, Best Execution, Broker-Dealer, Candidate, Chief Compliance Officer, Code of Ethics, commissions, Communication, Compliance Violations, Deceit, Disgorgement, Dually Licensed, Fee Calculations, fees, Fines, investment management agreement, Penalties, policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance Policies, Risk, SEC Investment Adviser Compliance, SEC NEWS, Share Class Selection, Suitability, Violations, Whistleblower, Whistleblower Protection Rule
On September 25, 2024, the SEC charged two firms with ignoring clients’ instructions and exceeding their designated investment limits for over two years. The two firms charged were Merrill Lynch, Pierce, Fenner & Smith Inc. (“Merrill Lynch”), a registered...
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 | Sep 28, 2023 | ADV Part 2A, ADV Part 2B, Books and Records, Business Continuity and Disaster Recovery Plans, Chief Compliance Officer, Client Relationship Summary, compliance deficiencies, Cybersecurity, Deficiencies, Examination Priorities, Fee Calculations, Form ADV, FORM CRS/Form ADV Part 3, Hedge Clause, Investment Adviser Representative, North American Securities Administrators Association (NASAA), policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, Safeguards Rule, State Investment Adviser Compliance
On September 11, 2023, the North American Securities Administrators Association (NASAA) released examination statistics that should serve as a wake-up call for state-registered investment advisers. A series of coordinated examinations of Registered Investment Advisers...
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...
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