Frequently Asked Questions: Trade Aggregation

posted in: Trade Practices | 0

These Frequently Asked Questions are part of a series of frequently asked questions that address four primary areas of interest to investment advisers:      Compliance Program Components;      Daily Operations;      Client Protection; and      Registration … Continued

For 2 Advisers Cherry Picking Season is Over!

posted in: Trade Practices | 0

In two separate administrative actions, the SEC barred two state-registered investment adviser for allocating trades in client accounts in a manner that disadvantaged their respective clients. The SEC also fined the heck out of them.

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

SEC Cybersecurity Exam Requests

posted in: Privacy & Data Security | 0

Cybersecurity seems to be all the rage with both SEC and state regulators. However, advisers have been flying blind as to what the regulators may actually request during a cybersecurity exam. Thanks to our contacts in the industry, we were able … Continued

SEC Issues Guidance Re: Inadvertent Custody

posted in: Custody | 0

Maybe there is something wrong with a rule that needs continual guidance? See the latest SEC Investment Management Guidance:  Inadvertent Custody: Advisory Contract Versus Custodial Contract Authority

Top 3 Custody Deficiencies

posted in: Custody | 0

As stated in the recent SEC Risk Alert, the 3 most frequent custody issues identified in examinations of investment advisers are as follows:

SEC 2017 Examination Priorities

posted in: SEC Examinations | 0

The SEC’s Office of Compliance Inspections and Examinations has published its examination priorities for 2017. The priorities focus on electronic investment advice, money market funds, and financial exploitation of senior investors. In addition, the priorities “reflect a continuing focus on … Continued

Way to Go CCO Companion!

posted in: Compliance | 0

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

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