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 … Read More
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 … Read More
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 … Read More
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 … Read More
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]
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 … Read More
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 … Read More
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 … Read More
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 However, regardless of whether the rule gets delayed or repealed, the Securities and Exchange Commission (“SEC”) continues to focus on the services being … Read More
“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, … Read More