Investment advisers are regulated entities subject to various securities laws. State registered investment advisers are subject to the regulations of each state the firm is registered with; however, those are not the only securities laws that can apply to … Read More
The COVID-19 pandemic has upended our personal and professional lives and many businesses are adjusting to this new environment in which working from home could be the new normal for an extended period of time. Since many firms have shifted … Read More
Registered investment advisers (“RIAs”) and their employees are fiduciaries to their clients. As such, they are tasked with ensuring that the services being provided to clients are appropriate and in their best interest. The Securities and Exchange Commission (“SEC”) describes … Read More
A month ago, it was unclear of how much COVID-19 (the “coronavirus”) would impact all of us in every facet of our lives. For some, we are indefinitely “sheltered in” and are working remotely where possible. Others must take care … Read More
During 2019, the Securities and Exchange Commission (“SEC”) issued an abundance of enforcement actions against financial firms, issuers, and auditors that involved disclosure deficiencies.[1] For financial firms, a majority of these circled around inaccurate, incomplete, or lack of disclosures involving … Read More
What is “Outsourcing”? Outsourcing can be defined as the act of contracting certain work or services out to a third party, typically as a replacement for conducting that service internally. In today’s market, many organizations choose to outsource specific, everyday … Read More
Managing Conflicts Managing a broker dealer’s gifts and business entertainment conflicts can be an ongoing challenge for even the best compliance team. This task can become even more challenging as the holidays approach. You want to thank your clients for … Read More
Proper Portfolio Management and Trading are Regulatory Priorities: In its 2019 Examinations Priorities Letter, the Securities and Exchange Commission (“SEC”), Office of Compliance Inspections and Examinations, listed Portfolio Management and Trading as SEC Examinations priorities.[1] Many Firms are unaware of … Read More
As 2020 looms on the horizon, Chief Compliance Officers (“CCOs”) should begin laying out their compliance roadmaps for the New Year. An area of review that should undoubtedly be a part of CCOs’ 2020 planning is cybersecurity. Cybersecurity remained at … Read More
With another year winding down, compliance personnel needs to begin evaluating the status of compliance projects and schedule any remaining tasks to ensure completion. Consideration of any regulatory changes, guidance, and risk alerts issued during the year, emerging best practices … Read More