Because this year is a Leap Year, the deadline for filing your annual amendment is March 30th and not the usual March 31st. Also, once you are done with your annual amendment filing, you still have one additional “ADV” obligation … Continued
Congratulations to the team at Digital Compliance and the launch of their very first compliance app – CCO Companion. We are proud to be the sole content provider for all of CCO Companion’s original compliance material. We believe, and from early … Continued
With the SEC’s greater emphasis on risk-based exams, SEC examiners’ primary focus is on an adviser’s controls and procedures. As such, they will perform an evaluation of the effectiveness of those controls. Where those controls are found to be weak and ineffective, or … Continued
An investment adviser has a fiduciary duty to act in the best interests of its clients. A central tenant of this duty is full and fair disclosure of all material facts to clients. What you tell your clients about your … Continued
Investment advisers must be able to monitor what their supervised persons are saying about the firm in their social media posts and should be able to monitor what others are saying about the advisory firm.
Since most social media activity occurs off-site and through mobile phones, advisory firms need to have the capability of applying all their social media policies and procedures to mobile devices.
Advisory firms must be able to capture and archive the posts and tweets of their supervised persons. Firm’s also need to be able to conduct a key word search for problematic terms.
Social media posts are advertising. Any disclaimer that you would typically place on your advisory firm’s web site should also accompany any social media posts. Since the nature of social media is to allow third-parties to post comments, it is … Continued
Among top five social media issues for advisers . . . Written Policies & Procedures Advisory firms must develop a written policy and attendant procedures that outlines, at the very least: The types of social media platforms (e.g., Twitter, Linkedin, … Continued