Category: Examinations and Audits
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….
Anti-Money Laundering | Broker Dealer | Examinations and Audits | FINRA | Regulatory Filings
Broker-Dealer 2018 Regulatory Year in Review
Photo by rawpixel on Unsplash We’ve put together a list of rules, enforcement actions and regulatory developments for broker-dealers for 2018. We recommend that broker-dealers use this review as a resource when…
Best Execution | Cash Solicitation Rule | Compliance Programs | Conflicts of Interest | Cybersecurity | Examinations and Audits | Investment Advisers Act | Investment Company Act | Liquidity | Mutual Funds | Private Investment Funds | Share Class Selection Disclosure | Testing
Eleven Key Takeaways for Updating your Compliance Program in 2019: Investment Advisers, Mutual Funds, Hedge Funds and Private Equity Funds
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…
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…
Broker Dealer | Examinations and Audits | FINRA | FINRA Rules
Broker-Dealer To-Do List to Comply with FINRA Changes to Registration Rules
FINRA has implemented several new registration and designation requirements that member firms will need to address on October 1. See FINRA Regulatory Notice 17-30. The To-do List includes the following,…
Compliance Program Rule, Rule 206(4)-7 | Examinations and Audits | Hardin News | Training
Jaqueline Hummel to speak at Cincinnati Compliance Roundtable on SEC Exams
Jaqueline Hummel, Partner and Managing Director of Hardin Compliance Consulting will be providing an insider’s view from a consulting firm’s experience during 32 SEC investment advisers’ exams. The presentation will…
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
SEC EXAMINATIONS: COMPARING EXAM PRIORITIES TO RESULTS
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…
Examinations and Audits | FINRA | Supervision
Protecting Seniors, High Risk Brokers and Excessive Trading Top FINRA’s 2017 Priorities List
In its Annual Regulatory and Exam Priorities for 2017, FINRA asserts that it “has enhanced its risk-based surveillance and examination program to apply a nationally consistent approach to identify and focus on material…
Custody | Examinations and Audits | Form ADV
Advisers May Have Custody and Not Even Know it….
SEC exam staff has been finding a deficiency where most advisers don’t expect it. Recent SEC exams of registered investment advisers have included scrutiny of the standard custody arrangements that…
Examinations and Audits
Webinar on SEC Examinations
Thursday, June 9 On Thursday, June 9, Hardin Compliance Consulting and Focus 1 Associates conducted their first interview in the new “CCO Speaks” series. We interviewed CCO Steven Weiss at Roosevelt Investment…