Latest risk management updates

Broker-Dealer Annual Compliance Meeting Best Practices

Planning for the Task As the summer solstice approaches, now is a good time for broker-dealer compliance personnel to begin planning for the annual compliance meetings (“ACMs”), required under FINRA Rule 3110(a)(7).  Specifically, each registered representative and registered principal of a...

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Latest risk management updates

Creating A Strong Culture of Compliance

Every registered investment adviser and employees of the adviser have a fiduciary duty to put their clients’ interests ahead of their own. The Securities and Exchange Commission (“SEC”) has often emphasized that the key to a successful compliance program is having a strong culture of compliance...

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Best Execution Considerations for Investment Advisers

Every registered investment adviser has a fiduciary duty to seek best execution when placing transactions for clients.  In addition to seeking best execution, the Securities and Exchange Commission (“SEC”) has issued a variety of guidance stating that advisory firms must also perform and document...

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Your Compliance Arsenal: Essential Resources for Compliance in 2019

Most firms are actively engaged in reviewing their compliance programs during the first quarter of every year.  Reflecting and evaluating your supervisory structure and internal controls, particularly in light of regulatory examination priority areas is essential. SEC Risk Alerts amplify this and...

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What Disclosures Should be Considered for Your Form ADV Amendments

Now that we are in the first quarter of the new year, most registered investment advisers (“RIA” or “Firm”) are busy preparing their annual Form ADV amendment.  This annual amendment is due within 90 days of the end of the Firm’s fiscal year, and the majority of RIAs have a fiscal year end of...

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Implementing Technology as Part of a Compliance Program

The administration of an advisory firm’s compliance program can be a daunting task for any Chief Compliance Officer (“CCO”), let alone an experienced one. Regardless of the number of employees at an investment advisory firm or a CCO’s experience, regulators expect advisory firms to maintain a...

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Identifying and Mitigating Advisory Conflicts of Interest

Conflicts exist in every business.  However, investment advisers have a fiduciary duty to always put the interests of their clients ahead of their own.  There are several areas of an adviser’s business that have potential conflicts of interest and even certain activities that carry inherent...

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Staying Ahead of the Cybersecurity Curve: Part II

In September of this year, the Securities and Exchange Commission (“SEC”) charged Voya Financial Advisors, Inc. (“VFA”) with violating Rule 30(a) of Regulation S-P (“Privacy Safeguards Rule”) and Rule 201 of Regulation S-ID (“Identity Theft Rule”) due to VFA’s failure to take appropriate steps to...

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The Art to Performing Annual Reviews

Annual reviews are a required compliance task that must be completed by all investment advisers registered with the Securities and Exchange Commission (“SEC”).  However, many investment advisers   may not understand the regulatory intent and expectations for performing the mandatory annual review. ...

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Year End Compliance Checklist Considerations for Investment Advisers

 With the third quarter of 2018 coming to a close, it’s time for Chief Compliance Officers (“CCOs”) to start taking inventory and determine what compliance projects still need to be addressed. To assist with this process, we’re providing a detailed checklist that includes risk management tips...

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Staying Ahead of the Cybersecurity Curve

Cybersecurity and cyberattacks continue to dominate the news and the regulatory landscape in 2018.  It is projected that they will continue to remain prominent issues for financial institutions for the foreseeable future.[1] To anticipate future cyberattacks is a near impossibility; however,...

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Help Teach Your Clients How To Avoid Investment Scams

Clients Who Want To Chase the Latest Hot Investment Opportunity Can Be Exposed To Scams

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