Form CRS: Ongoing Obligations

Form CRS: Ongoing Obligations

21 July 2021

Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant The one-year anniversary of Form CRS has come and gone, yet there are still questions about delivery requirements and annual updates.  First and foremost, there is NO annual update requirement. However, there are a few important triggers with re-filing your Form CRS, as well asRead More »

OCIE Observations: Compliance Programs

OCIE Observations: Compliance Programs

04 January 2021

Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant   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 andRead More »

Risk Alert: Employee Supervision and Employing Personnel with Disciplinary Events

Risk Alert: Employee Supervision and Employing Personnel with Disciplinary Events

28 August 2019

Main Contributor: Elizabeth Cope, CPA, CSCP, CIPM, CEO & Lead Consultant   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”).  NearlyRead More »