Compliance Solutions for Investment Advisers

Category Archives: State Compliance

Massachusetts to Check Criminal Backgound

The Office of the Secretary of the Commonwealth, Securities Division is registered under the provisions of MASS. GEN. LAWS c. 6, § 172 to receive and review Criminal Offender Record Information (“CORI”) for the purpose of screening current registrants and otherwise qualified prospective registrants.   Subsequent to January 1, 2014 and pursuant to a change in

Policy Statement on Custody Requirements

In conjunction with the release of a preliminary report describing an initiative by the Registration, Inspections, Compliance and Examinations Section of the Massachusetts Securities Division of the Office of the Secretary of the Commonwealth (the “Division”) to examine advisers that registered with the Commonwealth as a result of the Dodd-Frank Act (“Switch Advisers”), the Division issued a policy

Minnesota IARs of SEC Firms Now Required To Register

Prior to now, investment adviser representatives of SEC-registered investment advisers that were located in Minnesota did not have to register with state regulators (unless that had an office in the state). An Order dated October 31, 2013, has been issued by the Minnesota Department of Commerce regarding the “Implementation of Registration Process for Investment Adviser Representatives.”  According to

Enforcement Report

An enforcement report from the North American Securities Association slated for release this Thursday (November 7, 2013) finds the following deficiencies among mid-sized firms that made the switch from SEC to State registration: Unlicensed investment adviser representatives; Failing to document suitability in their investment recommendation; and Not providing appropriate privacy notifications to clients. All easily