30 October 2020
On September 15th, the SEC issued a Risk Alert to address a method of cyber-attack that is more sophisticated yet increasingly accessible to attackers: “credential stuffing.” We’re getting close to Thanksgiving, but that’s not the direction the SEC is going. This method of cyber-attack involves using compromised client login credentials to gain unauthorized access toRead More »
01 September 2020
On August 12th the SEC issued a Risk Alert outlining observations from exams and risks in light of the COVID-19 work from home environment. The Commission outlined six (6) areas of concern for firms to review and adjust policies and procedures as necessary, focusing on operational, technological, commercial and other challenges identified. Below we highlightRead More »
04 August 2020
On July 10th the SEC issued a risk alert focusing on ransomware and the importance of generating awareness within advisory firms of current threats. The SEC is encouraging registrants to monitor alerts provided by the Department of Homeland Security Cybersecurity and Infrastructure Security Agency (CISA) and share the information gathered with third party service providersRead More »
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 »
22 July 2019
Once again, the SEC has provided insight into exam deficiencies. This time, it’s regarding Reg S-P. Reg S-P requires, among other things, that registered investment advisers: provide customers with a copy of the Firm’s Privacy Notice initially and annually, if there are changes; provide customers with an option to opt out of personal informationRead More »
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 »
21 February 2019
Each year, the SEC publishes their exam priorities. This provides advisers with transparency in OCIE’s examination program and highlights areas that the SEC believes are of heightened risk. Unlike last year (when OCIE announced a focus on cryptocurrencies) there is nothing brand new this year that we haven’t seen in previous years. It’s kind ofRead More »
04 October 2018
In September 2018, an advisory firm was charged by the SEC and had to pay fines of $1 million dollars. Laying the Foundation This advisory firm is dually-registered (Broker Dealer and RIA). For a five-year period, independent contractors were provided access to client information through a remote web portal. The independent contractors used their ownRead 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 »