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Firms are encouraged to self-report issues to regulators when found. These self-reported items are generally resolved more favorably to the firms than they might be if found by the regulators…
As disclosed on a recent FINRA filing of Securities and Exchange Commission (“SEC”) Form 19b–4, there are proposed rule changes filed regarding registration and Continuing Education (“CE”) requirements: To restructure…
In response to the increased financial exploitation of seniors, the SEC recently approved the adoption of new FINRA Rule 2165: Financial Exploitation of Specified Adults and amendments to FINRA Rule…
One area of compliance commonly overlooked by many registered investment advisers is that of employee personal trading. In most instances, this is because many registered investment advisers assume they have…
On February 17, 2017, the North American Securities Administrators Association (“NASAA”) and the Securities and Exchange Commission (“SEC”) entered into a Memorandum of Understanding (“Memorandum”) regarding the treatment of non-public…
Per the SEC, “As an investment adviser, you are a “fiduciary” to your advisory clients.” Most states do not define registered investment advisers as fiduciaries within their statues, but defer…
Cyber-attacks seem to be more common. In turn, RIA firms are seeking greater risk protection with a focus on obtaining additional insurance coverage. Wading through the various types of errors…
During January, the SEC and FINRA published their 2017 examination priorities letters (click here for SEC letter and click here for FINRA letter). These are the top exam priorities enumerated…
So often I hear individuals tell me that one of the reasons they are leaving the broker dealer community to set out on their own and start their own investment…
In a recent decision by the U.S. Court of Appeals for the 10th Circuit, the SEC’s hiring process for administrative law judges (“ALJs”) was found to be in violation of…
Fee calculations are one of the most overlooked compliance issues in the registered investment adviser community. For those who employ a simple fee structure, such as, fees are billed quarterly…
The SEC has made it clear that cybersecurity has been and will likely remain an examination priority. A new Acceptance, Waiver and Consent was recently published by FINRA and it…
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