Latest risk management updates

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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Latest risk management updates

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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Form ADV Tips: What You Should Think About Before Filing

February 21, 2018

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 Form ADV for updates in March, this year needs to...

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How SEC Issued Investor Bulletins Can Help Your Firm

January 18, 2018

For almost a decade, the Securities and Exchange Commission (“SEC”) has been issuing write-ups focused on providing investors with timely information on investment frauds and scams (“Investor Alerts”), along with education on various investment topics (“Investor Bulletins”) (both types referred to...

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Risk Management Update: Risk Management Steps for Dealing with Inadvertent Custody

December 20, 2017

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 (the “Custody Rule”), having custody without adhering to the...

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Risk Management Update: Compliance Year-End Preparation Checklist

October 31, 2017

It’s time to start thinking about all the compliance projects that need to be completed before the end of the year.  While the Securities and Exchange Commission (“SEC”) slowed their pace on adopting new regulations during 2017, they continue to bring enforcement actions against investment advisers...

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New York’s Cybersecurity Requirements for Financial Services Companies

October 19, 2017

In 2017, the State of New York’s Department of Financial Services (“DFS”) adopted new requirements for financial services companies (“Covered Entities”)[1] to create and maintain robust cybersecurity policies and programs in a continuing effort to thwart cybercrimes and large scale cyber-attacks,...

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Important Risk Management Protocols to Consider for Alternative Investments

September 20, 2017

Risk Management Update September 2017 In an ongoing effort to diversify into non-market correlated investments, more and more advisory firms are offering strategies that include alternative investments. This term is broadly used in the industry and encompasses several types of assets, including but...

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What Advisers Need to Know About Wyoming's New Investment Adviser Regulations

August 25, 2017

On July 1, 2017, the State of Wyoming's new regulations became effective, which require certain investment advisers ("IAs) and investment adviser representatives ("IARs") to register with the State in order to provide investment advice in Wyoming. [1]

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What Advisers Need to Do to Prepare for Upcoming Changes to Form ADV

June 26, 2017

In their continued quest to obtain “big data” from registrants, the U.S. Securities and Exchange Commission (“SEC”) issued a final rule in August 2016, which significantly expands the information required in Form ADV.[1]  The compliance date for the rule is October 1, 2017, and all investment...

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Compliance Protocols for Dealing with Current Cybercrimes

May 17, 2017

According to a Data Breach Investigations Report published by Verizon in 2016,[1] there has been a definite upward trend in the number of people clicking on “phishing” emails since 2014.  Phishing is a type of social engineering used by hackers to trick people into introducing a virus into their...

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2017 Solutions for Compliance Professionals

April 18, 2017

At the beginning of every year, the Securities and Exchange Commission’s (“SEC’s”) Office of Compliance Inspections and Examinations (“OCIE”) identifies its examination priorities for the coming year. These priorities, which are based on perceived heightened risks to investors and the U.S. capital...

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Beyond the DOL Rule - A Look at SEC Expectations for Advisers Managing Retirement Accounts

March 21, 2017

The fate of the Department of Labor’s (“DOL”) Conflicts of Interest rule (the “DOL Rule”) is uncertain. However, regardless of whether the rule gets delayed or repealed, the Securities and Exchange Commission (“SEC”) continues to focus on the services being provided by investment advisers to...

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Why Investment Advisers Should Perform Annual Risk Assessments

February 20, 2017

"Risks applicable to investment advisers continue to be a high priority focus for the Securities and Exchange Commission (“SEC”).  To that end, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) is tasked with the responsibility of, among other things, monitoring risk applicable...

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