by Ara Jabrayan | Sep 5, 2024 | "Off-Channel" Communications, Best Execution, Books and Records, Chief Compliance Officer, Code of Ethics, Communication, compliance deficiencies, Compliance Violations, Conflicts of Interest, Cybersecurity, Deceit, Deficiencies, Division of Enforcement, Division of Examinations, Duty of Care, Electronic Communications Archiving Service, Fiduciary Duty, Fines, FINRA, Fraud, Investment Adviser Code of Ethics, Investment Adviser Representative, Investment Advisers Act, Investment Advisers Act - Section 206(4), policies and procedures, Recordkeeping, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), Restitution, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS
On August 12, 2024, the SEC announced that it had settled charges against a New York-based Registered Investment Adviser (RIA). The SEC ordered the RIA to pay over $6 million and to return funds to clients who were harmed by the firm’s undisclosed conflicts of...
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 | May 15, 2023 | 12b-1 Fees, Account Recommendations, Best Execution, Chief Compliance Officer, Client Relationship Summary, Code of Ethics, DOL Fiduciary Rule, Duty of Care, ERISA, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, Investment Advisers Act, policies and procedures, Registered Investment Advisers (RIAs), Regulation Best Interest (BI), Retail Investors, RIA Compliance, Risk, Robo-Advisers, SEC Investment Adviser Compliance, SEC Staff Bulletin, Standards of Conduct, State Investment Adviser Compliance, Suitability
On April 20, 2023, the SEC published a staff bulletin in a question-and-answer format to reinforce the standards of conduct owed by broker-dealers and Registered Investment Advisers (RIAs) when they are giving investment advice and making recommendations to retail...
by Ara Jabrayan | Oct 8, 2021 | Department of Labor, ERISA, Fiduciary Duty, Investment Adviser Representative, Investment Advisers Act, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Rules, Solicitation, Uncategorized
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...
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