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 »

Key Take-Aways from Recent Industry Conferences: Senior Investors & Private Funds

08 May 2019

  We wanted to share with you the common themes we’ve observed among the recent industry conferences we attended.  Let us know if we can help you with any of these topics. Senior Investors It was discussed that the SEC views senior investors as the most vulnerable investor group and considers it the investment advisers’Read More »

5 Tips to Simplify a CCO’s Heavy Workload

5 Tips to Simplify a CCO’s Heavy Workload

03 April 2019

    In all of my experience, working with CCOs as a compliance consultant, the one common sentiment they share is overwhelm.  Especially those who wear multiple hats (which is most of the CCOs I work with). If that’s you, you probably ask yourself, “How do I fit all of this in?!” In first quarter,Read More »

Overcoming the Challenges of SEC Compliance around Electronic Messaging

Overcoming the Challenges of SEC Compliance around Electronic Messaging

01 March 2019

  Did you see the SEC’s Risk Alert on Electronic Messaging? We did!  And let us start by saying, this Risk Alert was actually really helpful! A lot of times, the SEC issues Risk Alerts that tell you the issues they’re seeing in recent SEC examinations and remind you of your compliance obligations, but theyRead More »

Senior Investors, SEC Exams, and Your Fiduciary Duty

Senior Investors, SEC Exams, and Your Fiduciary Duty

13 December 2018

The focus on retirement accounts and senior investors has been on the SEC’s National Exam Priorities for years.  However, it is especially so this year, and as the US population ages and more baby boomers enter retirement, the focus and concern for senior investors will continue to grow. Do you have a direct relationship withRead 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 »