Retirement account rollover recommendations remain a top focus of the Securities and Exchange Commission (“SEC”) and Department of Labor (“DOL”) examinations. While many advisers associate PTE 2020-02 with 401(k)-to-IRA rollovers, its application is broader and extends to many recommendations involving … Read More
In Part 1 of this series, we discussed the first two pillars of an effective suitability program: developing a comprehensive understanding of your client and thoroughly evaluating the investments you recommend. While these steps establish the foundation for suitable recommendations, … Read More
Every investment adviser understands their fiduciary duty to act in a client’s best interest. Despite this, many SEC enforcement actions result not from intentional client harm, but rather from preventable failures: insufficient understanding of a client and/or the client’s needs, … Read More
“Fundamentals win championships” Coach Marty asserted on the first day of practice. It became the ideology of the only sports team I was on that ever won a championship. It was my last year of playing inner-city baseball before going … Read More
Every advisory firm faces a foundational decision before it can take on clients: should it register with the U.S. Securities and Exchange Commission (SEC) or with its home state? For most firms, the answer turns on size and client base … Read More
The next compliance date for implementing the requirements under amended Regulation S-P is fast approaching.[1] To help you prepare, this month’s Risk Management Update (“RMU”) provides steps that are required to be implemented – but are being presented with … Read More
As regulatory expectations and operational complexities continue to grow, investment advisers and broker-dealers increasingly turn to technology and specialized service providers to meet their obligations efficiently and effectively. Outsourcing certain functions has become a strategic choice, offering access to deep … Read More
Operational disruptions are no longer hypothetical risks. Cyber incidents, natural disasters, technology outages, and key-person events have become increasingly common, and the Securities and Exchange Commission continues to emphasize operational resilience as a fundamental component of an adviser’s compliance program. … Read More
Another year in compliance is officially in the books — and yes, that’s worth celebrating. While 2025 did not introduce sweeping new rules, it reinforced a familiar reality for advisory firms: ongoing obligations still require ongoing effort. Custody audits, annual … Read More
In November, the SEC released their 2026 Examination Priorities List,[1] which for investment advisers reflect a notable return to foundational principles, with a strong emphasis on fiduciary duty and standards of conduct, accurate disclosures, and the overall strength of a … Read More