Creating a Robust Compliance Program
The Compliance Program
Are You a Level Fee Fiduciary?
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 … Read More
Mary Jo White Stepping Down as Chair of Securities and Exchange Commission
On November 14, 2016, Mary Jo White, SEC Chair, announced her plans to step down at the end of the Obama Administration. During her tenure, the SEC brought more than 2,850 enforcement actions and obtained judgements and orders that tallied … Read More
2016 Core Compliance Annual Compliance Symposium Materials
Thank you for attending our 5th Annual Compliance Symposium in Anaheim, CA. We hope you enjoyed meeting the team and were able to gain valuable insight into the changes impacting our industry today. In keeping with cybersecurity best practices, we … Read More
Compliance Year-End Preparation Checklist
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 … Read More
Form ADV | Investment Adviser | Risk Management Updates (RMU) | Securities and Exchange Commission (SEC)
SEC Releases Amendments to Form ADV and Other Investment Adviser Act Rules
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 … Read More
SEC Sweep Results in 13 Enforcement Actions Against Advisers for Advertising a Third-Party’s False Performance Claims
On August 25, 2016, the SEC issued press release 2016-167 detailing the results of an enforcement sweep leading to settlements with thirteen investment advisers for advertising a third-party’s false performance claims.
SEC Amends Rules Under Investment Advisers Act
At the end of August, the Securities and Exchange Commission (“SEC”) issued a release amending a number of rules under the Investment Advisers Act of 1940 (“Advisers Act”), as well as Form ADV, which is the registration and reporting form … Read More
Pitfalls of Performance Advertising by Investment Advisers
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 … Read More
SEC Files Complaint Against Former Professional Football Player
On August 10, 2016, the SEC filed a complaint in federal court against Merrill Robertson Jr., a former Philadelphia Eagles football player, with defrauding investors. Mr. Robertson, along with Sherman C. Vaughn, Jr., and the company they co-owned, Cavalier Union … Read More