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 »

How to Navigate the SEC’s Best Execution Risk Alert

How to Navigate the SEC’s Best Execution Risk Alert

02 August 2018

“Best execution,” is a subjective target that is difficult to measure, rank, or define.  In general, best execution is the effort of an adviser, to seek best price while also factoring in: expertise, sophistication, speed, and “the full range and quality of a broker-dealer’s services including, among other things, the value of research provided asRead More »

How to Prepare for ADV Part 2A Updates

How to Prepare for ADV Part 2A Updates

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 »

ADV Part 1 Changes

ADV Part 1 Changes

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 »

Advertising Risk Alert

Advertising Risk Alert

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 »