2 Most Common Registration Deficiencies

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The 2 most common registration deficiencies:

  1. Inconsistencies in responses to similar items found on Part 1 and Part 2 of Form ADV (e.g., Item 8C of Part 1A indicates that the adviser does not have investment discretion, but the adviser then discusses its discretionary authority in Item 16 of Part 2A).
  2. Inadequate or incomplete disclosures to Part 2 items (e.g., In response to Item 11 of Part 2A, adviser discloses that it buys and sells the same securities that it recommends to clients, but does not discuss the conflicts of interest associated with this practice).