On October 1, 2017, the SEC updated and expanded the information required in the Form ADV, which means that if your fiscal year ended on December 31, 2017, it’s time for you to start thinking about your annual Form ADV … Read More
Featured in the December 2017 edition of the National Society of Compliance Professionals (“NSCP”) Currents publication, our Lead Senior Compliance Consultant, Tina Mitchell, provides guidance on compliance and what you should be thinking about to prepare for 2018.
Determining whether or not your investment advisory firm has custody is not an easy task, but it is necessary. While having custody of client assets is not prohibited under Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended … Read More
With 2017 rapidly coming to a close, you’re probably thinking about Christmas and your end-of-year vacation. You also may be putting the last touches on your company’s annual review. The Securities and Exchange Commission (“SEC”) has required advisory firms to … Read More
Featured in the July 2017 edition of the National Society of Compliance Professionals (“NSCP”) Currents publication, our Lead Senior Compliance Consultant, Tina Mitchell, describes the essentials for advisors to prepare for the upcoming changes to Form ADV.
Annual reviews need to be done at least once every year or even more often. Some firms conduct reviews every quarter, rather than just once a year. For investment advisers registered with the Securities and Exchange Commission (“SEC”), annual reviews … Read More
It’s tempting, I know, to want to search online for a compliance review checklist you can simply download for the required annual review. Among the many requirements within the Investment Advisers Act of 1940, the annual compliance review requirement in … Read More
Regardless of size, investment advisers need to be aware of some common, and avoidable, mistakes that are often made when maintaining compliance programs. Some of these mistakes are at a high level, things that senior management should be aware of. … Read More
In 2017, the State of New York’s Department of Financial Services (“DFS”) adopted new requirements for financial services companies (“Covered Entities”)[1] to create and maintain robust cybersecurity policies and programs in a continuing effort to thwart cybercrimes and large scale … Read More
Michelle Jacko will be presenting, “Identifying and Managing Conflicts of Interest – With or Without the Rule” at the NSCP National Conference on October 16, 2017, from 1:55PM – 3:10PM (ET), in Washington, D.C.