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 | Aug 30, 2023 | Best Execution, Books and Records, Chief Compliance Officer, Client Relationship Summary, Code of Ethics, Fee Calculations, Fiduciary Duty, Investment Adviser Code of Ethics, Investment Adviser Representative, policies and procedures, Private Funds, RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules, Standards of Conduct, Wrap fee
On August 23, 2023, the SEC adopted new rules and rule amendments to enhance the regulation of private fund advisers. The SEC also updated Rule 206(4)-7 under the Investment Advisers Act, better known as the Compliance Rule, which applies to all Registered Investment... by Ara Jabrayan | Jul 28, 2023 | 12b-1 Fees, ADV Part 2A, Books and Records, Chief Compliance Officer, Client Relationship Summary, compliance deficiencies, Compliance Violations, Division of Enforcement, Division of Examinations, Duty of Care, Examination Priorities, Fee Calculations, Fiduciary Duty, Form ADV, Investment Adviser Representative, Office of Compliance Inspections and Examinations (OCIE), policies and procedures, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC Investment Adviser Compliance, SEC Rules, State Investment Adviser Compliance, Wrap fee, Wrap Program
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... 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 | Jul 27, 2021 | Division of Examinations, Examination Priorities, FORM CRS/Form ADV Part 3, Investment Adviser Representative, Registered Investment Advisers (RIAs), RIA Compliance, RIA Compliance Policies, SEC NEWS, Uncategorized, Wrap fee
Wrap fee programs have been on the SEC’s radar for quite a while. When the SEC published its annual examination priorities in 2017, 2018, and 2019, wrap fee programs were mentioned as putting investors at risk. On July 21, 2021, the SEC’s Division of Examinations...
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