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Did you know that you may have Custody?

Did you know that you may have Custody? In February of 2017, the SEC provided guidance on the Custody Rule regarding Standing Letters of Authorizations (“SLOAs”), First Person Transfers, and inadvertent custody. SLOAs While a client can provide a standing letter of authorization to move money between the client’s own...

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SEC Tightens Record-Keeping Requirement on RIAs Reporting Performance

  Background On August 25 2016, the Securities and Exchange Commission (the “SEC”) adopted amendments to Form ADV and Rules 204-2(a)(7) and (a)(16). The amendments to Investment Advisers Act Rule 204-2 will require advisers to maintain additional records related to the calculation and distribution of performance information. The purpose of...

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Cybersecurity 2 Initiative Shows Improvement But Firms Are Still Deficient

ria cybersecurity

  On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert containing examiners’ latest observations regarding cybersecurity. OCIE’s Cybersecurity 2 Initiative is a follow-up to its Cybersecurity 1 Initiative, which was launched in 2014. In its most recent cybersecurity initiative, staff from the...

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Combining old-school methodology with social media technology to open individual company 401(k) investment advice relationships

My individual company 401(k) retirement plan participant prospecting began in the summer of 1999. I started prospecting my existing clients. At the time, I wasn’t aware of any other investment advisor who was offering to analyze an individual investor’s company 401(k) retirement plan account. Today, providing investment advice to individual...

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Are you adequately disclosing your conflicts of interest?

On February 26, 2015, in her keynote address at the IA Watch 17th Annual IA Compliance Conference, Julie Riewe, Co-Chief of the Asset Management Unit within the Division of Enforcement (“AMU”), stated that, in nearly every ongoing matter, the AMU seeks “to examine, at least in part, whether the adviser...

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