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…

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…