Archive Of The Category ‘Uncategorized‘

SEC Risk Alert: Form CRS

SEC Risk Alert: Form CRS

08 May 2020

SEC Risk Alert: Form CRS On April 7, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) issued a risk alert to let advisors and broker-dealers know that, regardless of COVID-19,  it’s business as usual at the SEC and firms must continue to meet their filing and delivery obligations of Form CRS. OCIE will mostRead More »

Compliant Advertising: Breaking it Down – Part 2: Testimonials

Compliant Advertising: Breaking it Down – Part 2: Testimonials

25 October 2019

Review of Part 1: The Foundation In the first article of this series, we discussed the foundational information you need to know to ensure your marketing and advertising materials are in compliance with the SEC’s rules and regulations.  We helped you clearly understand: the SEC’s definition of an “advertisement.” What is considered an advertisement, whatRead More »

Risk Alert: Use of Third Parties for Network Storage

Risk Alert: Use of Third Parties for Network Storage

02 July 2019

As a reminder, a “Risk Alert” is the SEC’s way of giving you a heads up about patterns of deficiencies during recent examinations.  They can help you stay on top of your game. On May 23, 2019, the SEC issued a risk alert on utilizing third parties to host and store records.  Using a thirdRead More »

Good News!  The SEC made a U-Turn on Inadvertent Custody

Good News! The SEC made a U-Turn on Inadvertent Custody

25 June 2018

The SEC recently updated the Staff Responses to Questions About the Custody Rule (“Custody FAQ”).  And this time, it’s a relief! As you probably recall, in February 2017, the SEC said that advisers may have “Inadvertent Custody” due to language that is in the agreement between the custodian and the client, which caused much angstRead More »