New SEC Exam Document Request

posted in: SEC Examinations | 0

There appears to be a new section in the “standard” SEC examination request letter. It asks for due diligence procedures used by the advisory firm’s portfolio managers, investment committee or analysts used to select stocks. Then the letter requests specific … Continued

Changes to Massachusetts IAR Registration?

posted in: Registration & Licensing | 0

On March 15, 2013, the Massachusetts Securities Division (the “Division”) filed regulations proposing amendments with respect to investment adviser representative (“IAR”) applications.  If made effective, the IAR application process would change and may affect your firm’s registration process for all … Continued

New SEC Regulation SCI

posted in: Compliance | 0

The SEC has unanimously proposed new rules to require certain key market participants to have comprehensive policies and procedures in place surrounding their technological systems. The SEC’s proposal called Regulation SCI would replace the current voluntary compliance program with enforceable … Continued

Adviser Standards of Conduct

posted in: Code of Ethics | 0

The SEC has recently published a request for data and other information to assist the agency in considering whether to make new rules about the standards of conduct and regulatory obligations for broker-dealers and investment advisers when they provide personalized … Continued

SEC Risk Alert – Custody

posted in: Alert!, Custody | 0

The alert by the SEC’s Office of Compliance Inspections and Examinations (OCIE) comes after a review of recent examinations where significant deficiencies were identified showed custody-related issues in about one-third of the firms examined. The advisers’ deficiencies included: Failure to … Continued