7 Things Advisers Must Do To Avoid Custody

posted in: Custody | 0

A recent SEC No-Action Letter (Investment Adviser Association, February 21, 2017) clarified how an investment adviser can avoid having custody as a result of having a standing letter of instruction or other similar asset transfer authorization arrangement established by a client … Continued

3 Ways to Reduce Potential SEC Penalties

posted in: SEC Examinations | 0

One day you might find yourself in a situation where you have discovered – through the normal operation of your compliance policies and procedures or through your compliance testing – that your advisory firm has come up short in some significant manner. … Continued