06 April 2021
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 Saving for Retirement Information Security and Operational Resiliency Financial Technology (FINTECH) andRead More »
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 »
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 »
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 »
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 »
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 »
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 »