02 June 2021
Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant Background This article follows the first in our series, The Definition of an Advertisement, where we summarized the amended Marketing Rule’s definitions of an advertisement; specifically the elements covered under Prong 1 and Prong 2 of the definition. Part Two of our series will focusRead More »
06 April 2021
Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant 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 SavingRead More »
01 March 2021
Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant Background The SEC proposed and adopted the new Marketing Rule, (the “Rule”) which will eventually replace the current Advertising Rule (Rule 206(4)-1, originally adopted in 1961) and the Solicitation Rule (Rule 206(4)-3, originally adopted in 1979). The Rule is a complete rewrite of theRead More »
30 October 2020
Main Contributor: Gretchen Sturdivan, Creative Director & Client Service Manager 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-attackRead More »
24 September 2020
Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant 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 accreditedRead 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 »