Episode 93: Advisory Fee Billing
On episode 93 of the CCO Buzz podcast, we’re joined by Sr. Compliance Consultant Maggie Tavares to discuss the importance of adequate and accurate Advisory Fee Billing.
IARs Have Two Years to Complete Continuing Education or Risk Securities License Termination
Maryland has joined Mississippi and Vermont on a growing list of state jurisdictions using January 1, 2022, as the effective date for new continuing education (CE) requirements. Within those states, Investment Adviser Representatives (IAR) must annually complete twelve (12) CE … Read More
Policies and Procedures: 125 Million New Reasons to Revisit Books-and-Records Obligations
Regulators have sent a chilling message to the securities industry by imposing record fines for widespread and longstanding failures against J.P. Morgan Securities LLC, a subsidiary of JP Morgan Chase & Co., a multinational investment bank and financial services company. The … Read More
Regulatory Focus on the Accuracy and Adequacy of Advisory Fee Billing and Disclosures
On November 10, 2021 the SEC Division of Examinations (“Division”) issued a Risk Alert outlining deficiencies the Division found during their national exam initiative on advisory fees. The focus of this Risk Alert was supplementary to the Risk Alert on … Read More
How a Combination of Asset Growth and a Remote Workforce Can Create a Crisis of Supervision
Market gains since the Great Recession have rewarded investment firms with record assets under management. And the challenges posed by the COVID-19 pandemic have changed the way many of us work, perhaps for a long time.
Don’t Become Conflicted by a Potential Fiduciary Conflict of Interest
When it comes to the preparation and submission of required annual documents to the U.S. Securities and Exchange Commission (SEC), few regulatory filings demand the level of meticulous care that investment advisory firms must use in completing Form ADV. It … Read More
SEC to Focus on Compliance Issues Related to Suspicious Activity Monitoring and Reporting at Broker-Dealers and Mutual Fund Firms
On March 29, 2021, the U.S. Securities and Exchange Commission (“SEC”) Division of Examinations (“EXAMS”) issued a Risk Alert citing frequent shortcomings found in compliance reviews of Anti-Money Laundering (AML) reporting at broker-dealer and mutual fund firms. Find the Risk … Read More
How to Build an Effective Culture of Compliance
Often, when broker-dealers and investment advisory firms are sanctioned by the regulators, the question on everyone’s mind is: where was compliance? While most firms are required to have a designated Chief Compliance Officer (“CCO”), few have more than one compliance … Read More