Core Compliance Blog Spotlight

The SEC Waves a Cautionary Yellow Flag for Investment Advisers Associated with Wrap Fee Programs

The continued growth of investor assets participating in wrap fee programs has prompted regulators to maintain a sharp focus of the programs as part of an ongoing assessment of market-wide risks and matters of importance to retail investors saving for retirement. Read More
Core Compliance Blog Spotlight

SEC Enforcement Actions Send a Stark Message: The Transition Period for Form CRS Has Ended

If firms needed a resounding wake-up call regarding the importance of delivering newly required client relationship summaries (Form CRS) to retail investors in a timely manner, the U.S. Securities and Exchange Commission (SEC) has provided one. Read More

Interactive Brokers, LLC to Pay Penalties for Failure to File Suspicious Activity Reports

August 19, 2020

On August 10, 2020, the Securities and Exchange Commission (“SEC”) announced that Interactive Brokers, LLC (“IB” or the “Firm”) had agreed to pay $11.5 million in fines for failure to file Suspicious Activity Reports (“SARs”) in conjunction with trading micro-cap securities on behalf of its...

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SEC Charges Birinyi Associates, Inc. with Unfair Trade Practices and Compliance Failures

August 19, 2020

On July 31, 2020, the Securities and Exchange Commission (“SEC”) announced it was charging Connecticut-based investment adviser, Birinyi Associates, Inc. (“BA” or the “Firm”), with violations of Sections 206(2) and 206(4) and Rule 206(4)-7 thereunder (“the Compliance Rule”) of the Investment...

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SEC Charges Valic Financial Advisors in Two Separate Actions with Disclosure Failures and Mutual Fund Selection Violations

August 07, 2020

On July 28, 2020, the Securities and Exchange Commission (“SEC”) announced it was charging Houston-based financial services firm, Valic Financial Advisors, Inc. (“VFA” or the “Firm”), a dually-registered broker-dealer and investment adviser, in two separate actions for violations of Section...

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SEC Releases Risk Alert on Cybersecurity and Ransomware Attacks

July 24, 2020

On July 10, 2020, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) released a risk alert highlighting a recent increase in ransomware attacks against financial industry participants.

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NASAA Released Proposed Model Compliance Rule

July 16, 2020

On July 2, 2020, the North American Securities Administrators Association (“NASAA”) released a notice for public comment on its proposed model rule for investment adviser written policies and procedures (“the Model Rule”) under the Uniform Securities Acts of 1956 and 2002 (“the Acts”).

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DOL Proposes New Class Exemption Rule

July 09, 2020

On June 29, 2020, the U.S. Department of Labor (DOL) proposed its new class exemption rule  (the “Rule”) designed to replace the 2016 Best Interest Rule that was vacated by the U.S. Court of Appeals for the Fifth Circuit (“the Fifth Circuit”) in 2018.

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Top 3 Considerations for Conducting an Annual Review

June 16, 2020

Under Rule 206(4)-7 (“Compliance Rule”) of the Investment Advisers Act of 1940 (“Advisers Act”), Investment Advisers (“RIAs”) that are registered with the Securities and Exchange Commission (“SEC”) must perform an annual review of the RIA’s policies and procedures (“P&Ps) to “test their adequacy...

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NFA Permanently Bars Hong Kong Futures Firm

June 11, 2020

On June 1, 2020 the National Futures Association (“NFA”) permanently barred Hong Kong-based commodity pool operator Bainbridge Asia Limited (“BAL” or the “Firm”) and its sole principal and associated person, Wai Man Yip, from membership and acting as a principal of an NFA member on the basis of...

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SEC Charges Private Equity Firm with Compliance Failures

June 05, 2020

On May 26, 2020, the Securities and Exchange Commission (“SEC”) announced that Los Angeles-based private equity firm and registered investment adviser, Ares Management LLC (“Ares” or the “Firm”) agreed to a cease-and-desist order, censure, and to pay a $1 million fine to settle charges that it...

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FINRA Updates Web CRD and IARD Security with Multi-Factor Authentication

May 21, 2020

The Financial Industry Regulatory Authority (“FINRA”) has upgraded the Web Investment Adviser Registration Depository (“IARD”) and Central Registration Depository (“CRD”) to include multi-factor authentication (“MFA”) in an effort to make the websites more secure:

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