Often, the difference between safety from a regulator and an enforcement action is knowing where the regulatory lines are drawn and what conduct constitutes an act that crosses those lines. Among the murkiest areas of regulatory concern is Custody. It’s … Read More
In October, The U.S. Securities and Exchange Commission (“SEC”) issued their 2024 exam priorities list,[1] which is only the second time in 10 years that they have released the list prior to year-end. Prior release dates have usually been in … Read More
An investment adviser has custody of client assets if it holds, directly or indirectly, client funds or securities, or if it has the authority to obtain possession of those assets.[1] An investment adviser with custody of client assets must: ensure … Read More
Core Compliance has published a number of items on the North American Securities Administrators Association Investment Adviser Representative Continuing Education Model Rule over the past few years and, in light of some recent activity among various states adopting the … Read More
For investment professionals, there are a seemingly endless array of rules and regulations to consider when reviewing a client’s existing investments and considering new investments to recommend. In this month’s Risk Management Update, we take a look at a few … Read More
“Familiarity breeds contempt” It’s an old saying that proves itself relevant again and again. When looking over the headlines or through the trade publication emails that fill our inboxes, even the most casual observer can find examples of someone whose … Read More
In July 2019, the US Securities and Exchange Commission (“SEC”) issued interpretive guidance on the standards of conduct for investment advisers.[1] The guidance outlines an investment adviser’s duty of care and loyalty as a fiduciary to its clients and specifically … Read More
In February of 2022, the SEC proposed Cybersecurity Risk Management Rules and Amendments (the “Proposed Rules”) that continue to focus on cybersecurity risks as an unavoidable reality for the financial markets and, specifically, for registered investment advisers who “increasingly depend … Read More
As the world of compliance in the investment advisory and broker-dealer spaces continues to evolve and the scope of required services expands, compliance professionals in the industry are leveraging technology and third-party vendors more than ever to meet the demands … Read More
When a regulator shows its hand, take it seriously—a poignant lesson that one is wise to heed. At the end of January, the Securities and Exchange Commission (“SEC”) released a Risk Alert entitled ‘Observations from Broker-Dealer Examinations Related to Regulation … Read More