An enforcement report from the North American Securities Association slated for release this Thursday (November 7, 2013) finds the following deficiencies among mid-sized firms that made the switch from SEC to State registration:
- Unlicensed investment adviser representatives;
- Failing to document suitability in their investment recommendation; and
- Not providing appropriate privacy notifications to clients.
All easily rectified (and avoided).
2012 enforcement actions resulted in $694 million in restitution and $115 million in fines and penalties.