Risk Alert: Common Reg S-P Deficiencies

Risk Alert: Common Reg S-P Deficiencies

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 »

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 »

Resources for How to Address the SEC’s 2019 Focus Areas

Resources for How to Address the SEC’s 2019 Focus Areas

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 »

Key lessons from Another Adviser’s mistakes…

Key lessons from Another Adviser’s mistakes…

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 »

SEC 2018 Exam Priorities – How do they affect you?

SEC 2018 Exam Priorities – How do they affect you?

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 »