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 30, 2023 | Account Recommendations, Advertising, Chief Compliance Officer, Code of Ethics, compliance deficiencies, Compliance Violations, Conflicts of Interest, Division of Enforcement, Division of Examinations, Emerging Technologies, Examination Priorities, Form ADV, Investment Adviser Code of Ethics, Investment Adviser Representative, Marketing Rule, policies and procedures, Press Releases, Registered Investment Advisers (RIAs), Retail Investors, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC NEWS, SEC Rules, Social Media, Social Media White Paper, Solicitation, Standards of Conduct, State Investment Adviser Compliance
Although the Cash Solicitation Rule was incorporated in part in the Marketing Rule, there are lessons to be learned from a recent enforcement action. On August 22, 2023, the SEC settled charges against a Registered Investment Adviser (RIA) based in Washington, D.C....
by Ara Jabrayan | Jul 24, 2023 | Advertising, Chief Compliance Officer, Code of Ethics, Compliance Violations, Division of Enforcement, Division of Examinations, Examination Priorities, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Press Releases, RIA Compliance, RIA Compliance Policies, Risk, SEC Investment Adviser Compliance, Social Media, Solicitation, State Investment Adviser Compliance
On September 19, 2022, the SEC’s Division of Examinations published a Risk Alert dealing with the Commission’s initial areas of review of Registered Investment Advisers’ (RIAs) compliance with the Marketing Rule. In its latest Risk Alert published on June 8, 2023, SEC...
by Ara Jabrayan | Apr 28, 2021 | Advertising, De minimis exemption, Registered Investment Advisers (RIAs), RIA Compliance, SEC Investment Adviser Compliance, SEC Rules
On December 22, 2020, the SEC enacted the new Marketing Rule, which will have an enormous impact on Registered Investment Advisers (RIAs). The new rule will replace the prior Advertising Rule, as well as the Cash Solicitation Rule. The SEC also amended Form ADV and...
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