3 Most Typical Books & Records Rule Deficiencies
Below are three typical examples of deficiencies or weaknesses with respect to the Books and Records Rule identified by the SEC staff:
Keeping Trade Confirmations
Recently an adviser asked if they still needed to keep trade confirmations since they were retained by their broker-dealer/custodian. I think an adviser must retain them in their books and records for three reasons: 1. The repository at the BD … Continued
SEC Hunting Down Performance Outliers
Make sure you can verify your performance numbers and that you maintain all records necessary to substantiate the performance. The SEC is hunting down performance outliers. If you are posting numbers that wildly outperforms a benchmark the SEC will take … Continued