2021 Exam Priorities: Discussion for Registered Investment Advisors

2021 Exam Priorities: Discussion for Registered Investment Advisors

06 April 2021

We finally have the 2021 Examination Priorities (“Priorities”) from the SEC, albeit later than previous years. You can read the release here. The Priorities for 2021 are strikingly similar to those of previous years, as noted below: Retail Investors, Including Seniors and Individuals Saving for Retirement Information Security and Operational Resiliency Financial Technology (FINTECH) andRead More »

OCIE Observations: Compliance Programs

OCIE Observations: Compliance Programs

04 January 2021

The SEC Risk Alerts keep coming, this time with exam observations regarding investment advisors’ Compliance Programs. According to OCIE, the most common exam deficiencies arise from issues with Rule 206-4(7), known as “the Compliance Rule.” Rule 206(4)-7 requires investment advisors to have policies and procedures reasonably designed to prevent, detect, and correct violations of theRead More »

SEC Risk Alert: Safeguarding Against Credential Compromise

SEC Risk Alert: Safeguarding Against Credential Compromise

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 »

SEC Amendments to the Accredited Investor Definition

SEC Amendments to the Accredited Investor Definition

24 September 2020

In August of this year, the SEC released an amendment to the “accredited investor” definition. What is an Accredited Investor? Certain qualifications must be met in order to invest in private placements or private funds. One qualification is being an “accredited investor.” An accredited investor must have an annual income of $200,000 (if single) orRead More »

Risk Alert: Employee Supervision and Employing Personnel with Disciplinary Events

Risk Alert: Employee Supervision and Employing Personnel with Disciplinary Events

28 August 2019

As part of the SEC’s focus on protecting retail investors, in 2017, they examined over 50 RIAs to assess the supervisory practices of advisers who (at the time) currently or previously employed personnel with a history of disciplinary events (the “Supervision Initiative”).  Nearly all of the advisers examined received deficiency letters. The Risk Alert recentlyRead More »