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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

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

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

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

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

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

New Guidance on COVID-19 Relief Relating to PPP Loan Eligibility, Form ADV Brochure Delivery, and more

On April 27, 2020, the Securities and Exchange Commission’s Division of Investment Management (the “SEC”) issued updated guidance concerning the following topics in response to COVID-19: Disclosure requirements for investment advisers applying for loans through the U.S Small Business Administration’s … Read More

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