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 »

Risk Alert: Use of Third Parties for Network Storage

Risk Alert: Use of Third Parties for Network Storage

02 July 2019

As a reminder, a “Risk Alert” is the SEC’s way of giving you a heads up about patterns of deficiencies during recent examinations.  They can help you stay on top of your game. On May 23, 2019, the SEC issued a risk alert on utilizing third parties to host and store records.  Using a thirdRead 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 »