Michelle Jacko Selected as Finalist for SDBJ CEO of the Year Awards 2020
CEO Michelle L. Jacko has been honored as a finalist for the “CEO of the Year Awards 2020” by the San Diego Business Journal.
Dually Registered Firms: Steps for Performing an Efficient Annual Review and Gap Analysis
In accordance with Rule 206(4)-7 of the Investment Advisers Act of 1940 (the “Act”), as amended, an investment adviser (“RIA”) registered with the Securities and Exchange Commission (“SEC”) is required to conduct an annual compliance review to assess the adequacy … Read More
SEC Clarifies FAQs on Legal and Disciplinary History Responses for Form CRS
On October 8, 2020, the U.S. Securities and Exchange Commission released updated guidance to help clarify questions that have surfaced regarding the information on the firm and employee disciplinary history that must be disclosed on the client relationship summary (Form … Read More
Area of Focus for Your Annual Review: Books and Records
The annual review is one of the three (3) pillars of Rule 206(4)-7 (“the Compliance Rule”) of the Investment Advisers Act of 1940 (“the Advisers Act”). The rule requires SEC-registered investment advisers (“RIAs”) to annually review “the adequacy of the … Read More
Episode 80: Vital Considerations for Conducting an Annual Review
On episode 80 of the CCO Buzz, Core Compliance discuss vital considerations for conducting an Annual Review.
A Change in State Oversight Prompts California’s Investment Advisors to Review Their Policies and Procedures
To help strengthen the state’s consumer protection laws and oversight of the financial industry, California has passed legislation that has changed the name of the Department of Business Oversight (DBO) to the Department of Financial Protection and Innovation (DFPI) and … Read More
IAA Compliance Corner: How to Improve Your Compliance Program
CEO Michelle Jacko’s article, “How to Improve Your Compliance Program,” was published in the October 2020 issue of the Investment Adviser Association’s (IAA) Compliance Corner Newsletter. In the article, Ms. Jacko provides readers with additional ways to improve their Compliance … Read More
Preparing for the U.S. Department of Labor’s Proposed Clarification on ERISA Proxy Voting
On August 31, 2020, the U.S. Department of Labor (DOL) released a proposal under the Employee Retirement Income Security Act of 1974 (ERISA) to amend fiduciary duties regarding proxy voting and shareholder rights. This particular rule is only in the … Read More
Episode 79: Are You Prepared for a Cybersecurity Sweep Exam?
On episode 79 of the CCO Buzz we discuss what firms should consider when preparing for a Cybersecurity Sweep Exam.
How to Prepare for a Cybersecurity Sweep Exam
Cybersecurity continues to be a top priority for the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations’ (“OCIE”), especially as the bulk of firms have had to shift to working remotely in light of COVID-19. Just in … Read More