On Monday, the SEC provided a press release regarding recent administrative and cease-and-desist proceedings against three different firms. These actions were centered around the validity of the compliance programs of the involved firms, and, in one case, the level of … Continued
Just a reminder that the deadline for payment of your firm’s annual renewal fees is December 12th. Don’t wait until the deadline to pay as the IARD system may take up to a week to process payments.
On November 2, 2011, the Massachusetts Securities Division proposed new regulations that would 1.) change the requirements for investment advisers with discretion or custody of client funds; 2.) change the definition of “institutional buyer” found in the regulations; and 3.) … Continued
The FINRA Entitlement Program provides authorized users a secure means to access participating applications with a single user ID and password. Once an investment adviser (IA) firm completes the entitlement process, it will obtain access to the IARD system in … Continued
The Texas State Securities Board is sending out the following email: “The Registration Division of the Texas State Securities Board is aware that your investment adviser firm may be required to switch from SEC registration to state registration as a … Continued
If you manage a private fund, the amount of information you are required to disclose in the new ADV Part 1 has increased tenfold (not sure how much tenfold actually is, but it is a lot). Instead of just listing … Continued
I commend you to read an excellent speech by Carlo di Florio, the Director of the SEC Office of Compliance Inspections and Examinations on the role of compliance and ethics in risk management. Here is the link: http://www.sec.gov/news/speech/2011/spch101711cvd.htm
Today began the annual registration renewal period. I have to say, the people at the IARD system are extremely helpful. Kudos to them.
Just a reminder that the annual registration renewal period begins on Monday, November 14th. Advisers must log on to their IARD account and obtain their firm’s Preliminary Renewal Statement. Fees must be paid by December 12th. Always best to start … Continued
Per the June release by the SEC in footnote 18, the SEC has raised the floor of assets under management above which advisers must register with the SEC to $110 million. However, they are permitted to register at $100 million. … Continued
Today starts the 30 day FINRA Certification Period for Super Account Administrators. According to the message sent out by FINRA: One of the responsibilities of FINRA Super Account Administrators (SAA) is to ensure that users in their organization who require … Continued