SEC Risk Alert: Safeguarding Against Credential Compromise

SEC Risk Alert: Safeguarding Against Credential Compromise

30 October 2020

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-attack involves using compromised client login credentials to gain unauthorized access toRead More »

SEC Amendments to the Accredited Investor Definition

SEC Amendments to the Accredited Investor Definition

24 September 2020

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 accredited investor must have an annual income of $200,000 (if single) orRead More »

COVID-19 Compliance Risks and Considerations for Investment Advisers

COVID-19 Compliance Risks and Considerations for Investment Advisers

01 September 2020

On August 12th the SEC issued a Risk Alert outlining observations from exams and risks in light of the COVID-19 work from home environment. The Commission outlined six (6) areas of concern for firms to review and adjust policies and procedures as necessary, focusing on operational, technological, commercial and other challenges identified. Below we highlightRead More »

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 »