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
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
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
Not long ago, the ability to invest in private offerings in the U.S. was limited to those whose annualized income and net worth afforded a country-club lifestyle. The requirements were an average income of $200,000 for the last two years … Read More
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
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 … Read More
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 … Read More
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 … Read More
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. The risk alert highlights the importance for financial … Read More
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 … Read More