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Dually Registered Firms: Steps for Performing an Efficient Annual Review and Gap Analysis

In accordance with Rule 206(4)-7 of the Investment Advisers Act of 1940 (the “Act”), as amended, an investment adviser (“RIA”) registered with the Securities and Exchange Commission (“SEC”)  is required to conduct an annual compliance review to assess the adequacy … Read More

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

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

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