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 | Division of Examinations, Fee Calculations, policies and procedures
On November 10, 2021, the SEC’s Division of Examinations (Division) published a Risk Alert containing examiners’ observations regarding investment advisers’ fee calculations. To arrive at these observations, examiners conducted approximately 130 examinations of... 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... by Ara Jabrayan | Sep 29, 2021 | 12b-1 Fees, Division of Examinations, Fiduciary Duty, Registered Investment Advisers (RIAs), RIA Compliance, SEC Rules, Uncategorized, Wrap fee
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... by Ara Jabrayan | Sep 28, 2021 | Cybersecurity, Investment Adviser Representative, Investment Advisers Act, Registered Investment Advisers (RIAs), Regulation S-P, RIA Compliance, RIA Compliance Policies, Safeguards Rule, SEC Cybersecurity, Uncategorized
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,...
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