For nearly a decade now, regulators have placed the Chief Compliance Officer (“CCO”) squarely within the sights of enforcement, on the logic that holding target CCO’s individually liable for violations would prompt robust compliance programs, and deter lackluster supervision. The reasonableness of such assumptions is a topic for a different post.  However, despite these drastically raised

calculatorOver the last three posts to the blog (overview, performance, promoters), we’ve interrupted our previous schedule to provide insight into the U.S. Securities and Exchange Commission’s (“SEC”) recently adopted changes to the rules governing investment adviser marketing and advertising. In today’s post, we resume our previous topic thread focusing on the


By Marc B. Minor

Investment advisers, rightly, focus much of their attention on satisfying their fiduciary duty through careful investment recommendations. However, advisers’ duties also include ensuring that client cash and securities are transferred for investment, and held, safely by the custodian of those assets.

For robo-advisers, client onboarding, facilitating the transfer of funds and