When you prepare your Form ADV annual amendment, the central task is capturing material changes since your last filing — new or changed conflicts of interest, fees, services, affiliations, and disciplinary events — and disclosing them clearly and completely. Now … Read More
As fiduciaries, investment advisory firms have a responsibility to identify and address risks that are applicable to their business practices and service offerings. Regulators continually remind firms of their responsibility through the issuance of speeches, written guidance, exam deficiency letters, … Read More
With the recent updates to the requirements for Form ADV, many firms are wrapping up the preparation for their Form ADV Annual Amendment filing. Most firms should have spent the last few weeks gathering specific data points to address the … Read More
The short answer: if your firm can direct client money to a third party under a standing letter of authorization, the SEC generally treats that as custody — which means it belongs on your Form ADV, and it can carry … Read More
Registered investment advisers (“RIAs”) that have a fiscal year-end of December 31st are currently faced with the impending deadline of March 31st for filing their annual amendment to Form ADV. While in the past RIAs may have begun reviewing their … Read More
On October 1, 2017, the SEC updated and expanded the information required in the Form ADV, which means that if your fiscal year ended on December 31, 2017, it’s time for you to start thinking about your annual Form ADV … Read More
Determining whether or not your investment advisory firm has custody is not an easy task, but it is necessary. While having custody of client assets is not prohibited under Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended … Read More
Annual reviews need to be done at least once every year or even more often. Some firms conduct reviews every quarter, rather than just once a year. For investment advisers registered with the Securities and Exchange Commission (“SEC”), annual reviews … Read More
Regardless of size, investment advisers need to be aware of some common, and avoidable, mistakes that are often made when maintaining compliance programs. Some of these mistakes are at a high level, things that senior management should be aware of. … Read More
