Latest risk management updates

Immediate Impacts of COVID-19 on Investment Adviser Compliance Programs

A month ago, it was unclear of how much COVID-19 (the “coronavirus”) would impact all of us in every facet of our lives.  For some, we are indefinitely “sheltered in” and are working remotely where possible.  Others must take care of loved ones and those who have special needs (due to illness,...

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Latest risk management updates

Forms ADV and CRS – Important Things You Need to Know

Update: (March 16, 2020) Since the original publishing of this Risk Management Update in February 2020, many details have changed in the securities industry due to the coronavirus (COVID-19) pandemic. Please find additional updated information regarding your Form ADV filings below.

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The Pros and Cons of Outsourcing Your Chief Compliance Officer (“CCO”)

What is “Outsourcing”? Outsourcing is defined as a way to obtain (goods or a service) from an outside or foreign supplier, especially in place of an internal source. In today’s market, many organizations choose to outsource specific every day critical tasks to outside experts. A prime example:  an...

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Gifts & Business Entertainment Conflicts - The Ongoing Challenge for Broker-Dealers

Managing Conflicts Managing a broker dealer’s gifts and business entertainment conflicts can be an ongoing challenge for even the best compliance team. This task can become even more challenging as the holidays approach. You want to thank your clients for their business, but you should also remind...

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Compliance Considerations of Portfolio Management and Trading

Proper Portfolio Management and Trading are Regulatory Priorities: In its 2019 Examinations Priorities Letter, the Securities and Exchange Commission (“SEC”), Office of Compliance Inspections and Examinations, listed Portfolio Management and Trading as SEC Examinations priorities.[1]  Many Firms...

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Cybersecurity Considerations to Address in Preparation for 2020

 As 2020 looms on the horizon, Chief Compliance Officers (“CCOs”) should begin laying out their compliance roadmaps for the New Year. An area of review that should undoubtedly be a part of CCOs’ 2020 planning is cybersecurity. Cybersecurity remained at the top of the Securities and Exchange...

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Year End Compliance Checklist Considerations for Investment Advisers

With another year winding down, compliance personnel need to begin evaluating the status of compliance projects and schedule any remaining tasks to ensure completion.  Consideration of any regulatory changes, guidance and risk alerts issued during the year, emerging best practices and enforcement...

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Updates and Changes to Your Firm's Policies and Procedures

Under Rule 206 (4) -7 all Registered Investment Advisers (“RIA’s) are required to have compliance Policies and Procedures, adequately designed to help them meet their regulatory requirements.  A Firm’s obligations regarding their Policies and Procedures manuals do not end at just having a manual. ...

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Cybersecurity Testing as Part of the Annual Review

Firms registered with the Securities and Exchange Commission (“SEC”) are mandated by Rule 206(4)-7 (“Compliance Rule”) to perform an annual review of their policies and procedures, and a key component of a firm’s annual review should include cybersecurity testing. Cybersecurity remains a top...

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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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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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