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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

Social Media – Monitoring

posted in: Advertising & Marketing | 0

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.

Social Media – Capture

posted in: Advertising & Marketing | 0

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 – Disclaimers

posted in: Advertising & Marketing | 0

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

Conduct Compliance Testing

posted in: Compliance | 0

“Forensic testing” is certainly the buzzword in compliance circles. Think CSI: Crime Scene Investigation. Essentially, an adviser should conduct some type of transactional or quality control tests that will assist the adviser in determining whether its activities are consistent with … Continued

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