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The typical SEC examination will reveal some compliance deficiencies or internal control weaknesses at the firm. When the firm’s compliance or internal control failures are deemed serious, such as when investor funds or securities are believed to be at risk,...
Learn MoreRecently the Securities and Exchange Commission (“SEC”) released a Risk Alert identifying the most common deficiencies found in third-party solicitor arrangements: Risk Alert. The SEC’s findings and observations are based on adviser examinations completed over the past three years. Rule…
Read MoreIt’s Complicated. It’s Way Too Complicated. The 2009 romantic comedy, It’s Complicated, is a humorous look at relationships. The relationship between Registered Investment Advisers (“RIAs”) and prospective clients is often made more complicated than it needs to be. I have…
Read MoreSEC Actions: In September 2018, the SEC found that: Citigroup violated an antifraud provision of the federal securities laws and that Citi Order Routing and Execution (“CORE”) failed to register as an exchange. Without admitting or denying the findings, Citigroup and…
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