Off-Channel Communications Will Lead to Record-keeping Violations

On August 8, 2023, the SEC charged eleven financial services firms, including a dually registered broker-dealer (BD) and Registered Investment Adviser (RIA), with widespread record-keeping violations. The firms acknowledged their wrongdoing and agreed to pay combined...

Fee Mistakes Will Cause Problems for Advisers

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...

SEC Adopted Amendments to Form N-PX Reporting Requirements

On November 2, 2022, the SEC adopted amendments to Form N-PX in order to fulfill one of the remaining mandates established by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Among other changes triggered by the amendments, institutional investment...

SEC’s Division of Examinations Risk Alert Regarding Observations from Examinations of Newly-Registered Advisers

On March 27, 2023, the SEC’s Division of Examinations (Division) published a Risk Alert that will be of great interest to newly-registered investment advisers. The observations will also be invaluable to investment advisers that have been in business for some years....