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 »
16 March 2018
If you’re an RIA, this article is for you. Have you taken a peek at the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) National Exam Program Examination Priorities for 2018? (Look for a fun acronym for that once we get through all the good stuff.) Below, we summarize the examination priorities relevant to registeredRead More »
27 February 2018
Don’t miss a deadline! We’ve put together a compliance calendar to help you keep track of regulatory filing deadlines and update your compliance calendar for 2018. You might want to bookmark this one! SEC Regulatory Deadlines for Investment Advisers We have included the filing deadlines in chronological order. Additional details, including definitions and descriptions ofRead More »
07 February 2018
Haven’t looked at your ADV Part 2A in months? Staring at your computer screen, wondering where to start? Check out our ADV Part 2A checklist. Did you have any major changes to your firm’s business in 2017? Make a list! Have you opened or closed any new products or funds in 2017? Do your productsRead More »
07 February 2018
On October 1, 2017, the U.S. Securities and Exchange Commission (“SEC”) amended the ADV Part 1 to obtain more information on registered investment advisers. As the annual amendment date (March 31st, 2018) closes in, we want to summarize important changes and remind you of important practices this filing season. SCS Suggests As you start yourRead More »
03 January 2018
SEC Chairman Jay Clayton recently issued a statement about the highly discussed topic of cryptocurrencies and initial coin offerings (ICOs) on December 12, 2017. He addressed main street investors and market professionals, which includes investment advisers and broker-dealers, among others. Clayton warned market professionals to review SEC investigative reports and subsequent enforcement actions. The conclusionRead More »
15 October 2017
As it stands today, the DOL’s Fiduciary Rule has been delayed to July 1, 2019. This delay to the ruling is a direct result of President Donald Trump’s executive order requesting the Department of Labor to conduct a review of the rule. Even though the rule is delayed, the DOL has stated that advisers mustRead More »
01 October 2017
An adviser’s use of marketing materials continues to be an area of high concern for the SEC, and with good reason. Marketing materials are how you showcase your firm to the world. They’re used to obtain investors, to grow the business, and find new opportunities. And you better believe the SEC is going to reviewRead More »