Best Execution | Code of Conduct | Conflicts of Interest | Disclosures | Examinations and Audits | Fiduciary

What Your Next Deficiency Letter is Going to Say: SEC Tells Advisers What Fiduciary Duty Means

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….

Best Execution | Cash Solicitation Rule | Chief Compliance Officer | Compliance Programs | Conflicts of Interest | Custody | Cybersecurity | Disclosures | Examinations and Audits | Mutual Funds | Private Equity Funds

SEC’s Top Eleven Hits: Investment Adviser Regulatory Review 2018

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…

Best Execution | Disclosures | Form ADV | SEC News | Share Class Selection Disclosure

The Real Nightmare Before Christmas: SEC Gets Tough on Firms that Did Not Self-Report during SCSD Initiative

Photo by Simon Matzinger on Unsplash The SEC’s Enforcement Division is following up on the Share Class Selection Disclosure Initiative (the “SCSD Initiative”) by sending out document requests to dually-registered investment advisers and…

Advertising and Marketing Regulation | Best Execution | Code of Ethics | Compliance Program Rule, Rule 206(4)-7 | Compliance Programs | Custody | Disclosures | Examinations and Audits | Form ADV


The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) is upfront about the areas it will be testing during its examinations of investment advisers.  In January, OCIE publishes its Examination…