As you prepare your update to Form ADV, pay particular attention to disclosure of conflicts of interest.  Everyone should have gotten the memo by now about disclosure of 12b-1 fees…

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…

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…

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…

With all the buzz about the passage of Regulation Best Interest (“Reg BI”), the “Commission Interpretation Regarding Standard of Conduct for Investment Advisers” (the “Interpretation”) has received much less attention….

Photo by NordWood Themes on Unsplash Cari Hopfensperger, Senior Compliance Consultant, co-wrote this article. Based on regulatory developments from 2018, here are our suggestions for updates to your compliance program for 2019. Conflict…

Photo by Mark Duffel on Unsplash The SEC’s regulatory actions in 2018 involved few surprises but still managed to challenge investment advisers.  In reviewing the SEC’s activity over the past 12 months, I…

On April 6, 2018, the SEC released three settlement orders with investment advisers because they “failed to disclose conflicts of interest and violated their duty to seek best execution by…

On February 12, 2018, the SEC Division of Enforcement announced a new self-reporting initiative – the Share Class Selection Disclosure (the “SCSD Initiative”).  The Initiative, led by the Commission’s Asset…

The first week of November was a time for surprises, but most surprising to me was the SEC’s decision in In re The Robare Group, Ltd.  Back in 2015, I…