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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Latest risk management updates

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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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 However, regardless of whether the rule gets delayed or repealed, the Securities and Exchange Commission (“SEC”) continues to focus on the services being provided by investment advisers to...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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Investment Advisers - What You May Not Know Could Affect Your Registration

January 27, 2017

There are many facets surrounding the registration of investment advisory firms (“IA Firm”) and investment adviser representatives (“IAR”) and the process can be erroneous if not performed correctly. Since registration is one of our core service offerings, we get asked a lot of questions from...

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Creating a Robust Compliance Program

December 06, 2016

The Compliance Program

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Are You a Level Fee Fiduciary?

November 21, 2016

The Department of Labor’s (“DOL’s”) Conflicts of Interest rule (“the DOL Rule”),[1] and its broad applications, will inevitably impact a wide range of retirement investors and most financial services firms that deal directly with investors.  As the DOL Rule will materially go into effect April 10,...

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Compliance Year-End Preparation Checklist

October 27, 2016

The end of 2016 is fast approaching and the financial services industry has been hit this year with some very important and complicated new regulations, such as the Department of Labor’s Conflicts of Interest Rule (“DOL Rule”) and the Securities and Exchange Commission’s (“SEC”) amendments to Form...

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SEC Releases Amendments to Form ADV and Other Investment Adviser Act Rules

October 03, 2016

In a press release dated August 25, 2016,1 the Securities and Exchange Commission (“SEC”) announced their issuance of a final rule, which amends Form ADV (Uniform Application for Investment Adviser Registration), along with five other rules under the Investment Advisers Act of 1940, as amended...

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Pitfalls of Performance Advertising by Investment Advisers

August 24, 2016

In this age of technology, advertising and marketing by investment advisers can be very economical and the venues numerous.  Advisers utilize websites, social media, blogs and blast messages as their main distribution channels and all of these mediums have far reaching capabilities. While the SEC...

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SEC Proposed Business Continuity & Transition Plan Rule: More than Just Disaster Recovery Planning

July 20, 2016

On June 28, 2016, the Securities and Exchange Commission (“SEC”) issued a proposal requiring SEC registered investment advisers to implement a written business continuity and transition plan (“BCTP”).1   In the corresponding press release,2 the SEC stated that the purpose of the proposed regulation...

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The DOL Conflicts of Interest Rule and How it May Affect You (Part 2)

June 24, 2016

Who is an ERISA Fiduciary?

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Enhancing Annual Reviews - Practical Considerations for Investment Advisers and Investment Companies

May 23, 2016

It’s been over a decade since the Securities and Exchange Commission (“SEC”) adopted Rule 206(4)-7 under the Investment Advisers Act of 1940, and Rule 38a-1 under the Investment Company Act of 1940. Despite the passage of time, Rule 206(4)-7 and 38a-1 (commonly referred to in the financial industry...

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