FINRA Entitlement Screw Up

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As if things weren’t confusing enough . . . From FINRA: You may have received a test email that was sent in error this morning with the subject line ‘Past Due: FINRA Entitlement User Accounts Certification’. The body of this … Continued

FINRA Reminds Firms of Their Obligations Regarding the Supervision of Registered Persons Using Senior Designations

FINRA is publishing this Notice to remind firms of their supervisory obligations regarding the use of certifications and designations that imply expertise,certification, training or specialty in advising senior investors (senior designations). This Notice also outlines findings from a survey of firms and … Continued

Recent SEC Proceedings

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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

Excellent Speech by the Head of OCIE

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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

SEC Postpones Fiduciary Rules

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The SEC (and the Department of Labor) postponed efforts to extend a fiduciary standard to more financial advisers. “It’s extremely unlikely that there will be a rule this year,” an SEC official says.

Compliance Alert! Special Concerns

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Dear Compliance Professional, The Compliance Alert below was originally sent out in 2008. Unfortunately, recent market events make the subject matter relevant once again. We will also be sending out other pertinent Compliance Alerts from 2008-2009. Background The purpose of … Continued

Proposed Changes to Massachusetts Adviser Regulations

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On April 21, 2011, the Massachusetts Securities Division released for comment proposed regulations that would affect registered investment advisers operating in Massachusetts. Investment Adviser Discretion and Custody Requirements The Division proposes to modify the minimum financial requirements for investment advisers … Continued

Compliance Alert!

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For your convenience, we will be posting archives of our Compliance Alert! newsletter on the Compliance “Best Practices” blog. They can be found in the category of the specific topic addressed (e.g., “Risk Assessment”) and will be filed as of … Continued