Business Continuity and Disaster Recovery | COVID-19 Pandemic | Regulatory Filings | State News

State Regulators Not Feeling So Graceful Now: Investment Adviser Representatives Who Relocated to Other States for Pandemic May Have to Register as Grace Periods End

State regulators recognize that the new “work from home” environment is here to stay.  Several have ended grace periods that allowed investment adviser representatives (IARs) to provide advisory services in…

Broker Dealer | Hardin News | Investment Advisers | Private Equity Funds | Private Placements | Referrals

Practical Thought Leadership – Common Myths About Finders, Solicitors, Unregistered Broker-Dealers and the “Issuer Exemption”

Hardin is pleased to share this recent contribution to the National Society of Compliance Professionals (NSCP)  Currents: Common Myths About Finders, Solicitors, Unregistered Broker-Dealers, and the “Issuer Exemption” by Partner…

Broker Dealer | Hedge Funds | Investment Advisers | Marketing and Sales Activities | Private Investment Funds

Common Myths about Finders, Solicitors, Unregistered Broker-Dealers, and the “Issuer Exemption”

In the financial services industry, whenever money changes hands, everyone involved in the process wants to get paid.  Investors understand that registered investment advisers and broker-dealers are compensated for their…

Annual Compliance Program Review | Compliance Programs | Conflicts of Interest | Cybersecurity | Disclosures | Investment Advisers | Seniors and Vulnerable Investors

SEC’s Top 10 Hits: Investment Adviser Regulatory Review 2019 – Part 2

Here the remaining top 5 hits from our investment adviser regulatory review. (Check out Part 1 here.) The SEC remains concerned about information security, including cyber-related risks, and 2020 is…

Annual Compliance Program Review | Compliance Programs | Conflicts of Interest | Cybersecurity | Disclosures | Investment Advisers | Seniors and Vulnerable Investors

SEC’s Top 10 Hits: Investment Adviser Regulatory Review 2019 – Part 1

Based on regulatory developments from 2019, here are our suggestions for updates to your RIA compliance program for 2020. The SEC’s top regulatory initiatives in 2019 defined the standard of…

Annual Compliance Program Review | Blue Sky Filings | Broker Dealer | Compliance Program Rule, Rule 206(4)-7 | Compliance Programs | Conflicts of Interest | Cybersecurity | Disclosures | Examinations and Audits | Form ADV | Investment Advisers | Mutual Funds | SEC Risk Alert | Seniors and Vulnerable Investors | States | Supervision |

SEC’s Top Eleven Hits: Investment Adviser Regulatory Review 2019

In addition to basic blocking and tackling, compliance officers often have the thankless job of performing the annual review of their compliance program required by Advisers Act Rule 206(4)-7.  As…