Cybersecurity continues to be a top priority for the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations’ (“OCIE”), especially as the bulk of firms have had to shift to working remotely in light of COVID-19. Just in … Read More
Registered investment companies (“RIC”) are regulated entities subject to various securities laws. One main regulation is Rule 38a-1 under the Investment Company Act of 1940, as amended (“40 Act”), which requires a RIC to adopt and implement a compliance … Read More
Proper Disclosures are a Fiduciary Responsibility One of the most important fiduciary duties of a Registered Investment Adviser (“RIA”) is that of disclosure. Current regulations require disclosure of many aspects of a RIA’s business including, among many things, ownership, business … Read More
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
Update: (March 16, 2020) Since the original publishing of this Risk Management Update in February 2020, many details have changed in the securities industry due to the coronavirus (COVID-19) pandemic. Please find additional updated information regarding your Form ADV filings … 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