In Part 1 of this series, we discussed the first two pillars of an effective suitability program: developing a comprehensive understanding of your client and thoroughly evaluating the investments you recommend. While these steps establish the foundation for suitable recommendations, … Read More
Every investment adviser understands their fiduciary duty to act in a client’s best interest. Despite this, many SEC enforcement actions result not from intentional client harm, but rather from preventable failures: insufficient understanding of a client and/or the client’s needs, … Read More
“Fundamentals win championships” Coach Marty asserted on the first day of practice. It became the ideology of the only sports team I was on that ever won a championship. It was my last year of playing inner-city baseball before going … Read More
Every advisory firm faces a foundational decision before it can take on clients: should it register with the U.S. Securities and Exchange Commission (SEC) or with its home state? For most firms, the answer turns on size and client base … Read More
The next compliance date for implementing the requirements under amended Regulation S-P is fast approaching.[1] To help you prepare, this month’s Risk Management Update (“RMU”) provides steps that are required to be implemented – but are being presented with … Read More
As regulatory expectations and operational complexities continue to grow, investment advisers and broker-dealers increasingly turn to technology and specialized service providers to meet their obligations efficiently and effectively. Outsourcing certain functions has become a strategic choice, offering access to deep … Read More
Operational disruptions are no longer hypothetical risks. Cyber incidents, natural disasters, technology outages, and key-person events have become increasingly common, and the Securities and Exchange Commission continues to emphasize operational resilience as a fundamental component of an adviser’s compliance program. … Read More
Another year in compliance is officially in the books — and yes, that’s worth celebrating. While 2025 did not introduce sweeping new rules, it reinforced a familiar reality for advisory firms: ongoing obligations still require ongoing effort. Custody audits, annual … Read More
In November, the SEC released their 2026 Examination Priorities List,[1] which for investment advisers reflect a notable return to foundational principles, with a strong emphasis on fiduciary duty and standards of conduct, accurate disclosures, and the overall strength of a … Read More
The digitization of communication continues with fervor. For the financial industry, this is parallelled by the continued development of associated rules and requirements as regulators work to stay in lockstep with technological advancements. As new platforms and methods of communication … Read More