If your firm offers a wrap fee program to clients or recommends that clients participate in a wrap program, now is an opportune time to review your fee disclosures and billing practices and best execution protocols. In July 2021, the U.S. … Read More
A recent filing by the U.S. Securities and Exchange Commission (“SEC”) against a California-based advisory firm should serve as a cautionary tale for compliance officers. It provides keen insight into the SEC’s ongoing effort to seek enforcement action against firms … Read More
At the beginning of 2021, the Securities and Exchange Commission (“SEC”) released its exam priorities report for the year.[1] In the release, the SEC stated the following: “The Division will continue to review the compliance programs of RIAs, including whether … Read More
Failure to disclose conflicts of interest. Making misleading statements. Creating positive incentives and negative pressures for its sales force. Failure to adopt and implement written policies and procedures.
U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler has directed the Commission to consider whether it should revisit 2019 guidance and 2020 rule amendments regarding proxy voting advice[1].
Using technology has become a very integral part of today’s business services, especially in the financial industry. Due to the changes in both state and federal securities regulations over the last few years, the need for financial firms to have … Read More
The Employee Retirement Income Security Act of 1974, as amended (“ERISA”), contains provisions that restrict fiduciaries to retirement plans from engaging in certain activities. These prohibited activities include, among other things, self-dealing, implementing principal transactions,[1] and receiving compensation from third … Read More
The North American Securities Administration Association (NASAA) is a voluntary body composed of state securities regulators across all 50 states, Canada, and Mexico. Founded in 1919, it is the oldest international regulatory organization devoted to investor protection.
The question of how many resources your firm should allocate to your compliance department to fulfill its regulatory responsibilities can be a hot button topic for investment advisory firms of all sizes.
This year will certainly be one for the history books. The worldwide pandemic continues to impact our country and the way we live. For the financial industry, we have witnessed evolutions and changes of focus in regulatory examinations.