Creating a Robust Compliance Program
The Compliance Program
Are You a Level Fee Fiduciary?
The Department of Labor’s (“DOL’s”) Conflicts of Interest rule (“the DOL Rule”),[1] and its broad applications, will inevitably impact a wide range of retirement investors and most financial services firms that deal directly with investors. As the DOL Rule will materially … Read More
Form ADV | Investment Adviser | Risk Management Updates (RMU) | Securities and Exchange Commission (SEC)
SEC Releases Amendments to Form ADV and Other Investment Adviser Act Rules
In a press release dated August 25, 2016,1 the Securities and Exchange Commission (“SEC”) announced their issuance of a final rule, which amends Form ADV (Uniform Application for Investment Adviser Registration), along with five other rules under the Investment Advisers … Read More
SEC Amends Rules Under Investment Advisers Act
At the end of August, the Securities and Exchange Commission (“SEC”) issued a release amending a number of rules under the Investment Advisers Act of 1940 (“Advisers Act”), as well as Form ADV, which is the registration and reporting form … Read More
Pitfalls of Performance Advertising by Investment Advisers
In this age of technology, advertising and marketing by investment advisers can be very economical and the venues numerous. Advisers utilize websites, social media, blogs and blast messages as their main distribution channels and all of these mediums have far … Read More
SEC Held Compliance Outreach Program for Investment Advisers and Investment Companies
On April 19, 2016, the Securities and Exchange Commission (“SEC”) held their National Compliance Outreach seminar, which covered a number of topics, including:
SEC Chair White Requests Additional Resources for Expanding Oversight of Investment Advisers
During her testimony to the U.S. Senate Subcommittee on Financial Services and General Government Committee on Appropriations, Chair White outlined the SEC’s top priorities for allocating the additional funding requested under their fiscal year 2017 (October 1, 2016, through September … Read More
SEC Chair White to Recommend Required Third-Party Compliance Reviews
In her testimony yesterday before the Committee on Financial Services of the United States House of Representatives SEC Chair Mary Jo White shared the following regarding third-party compliance reviews: At my direction, the staff is also preparing a recommendation to … Read More
SEC Fines Firm for Failure to Adopt Cybersecurity Policies and Procedures
Recently the Securities and Exchange Commission (“SEC”) charged a St. Louis Investment adviser that had experienced a breach of client non-public information with failing to create and implement cybersecurity policies and procedures. According to the SEC’s press release, for over … Read More