The exam is finally over! If your advisory firm has been undergoing an SEC examination, you’ve probably been waiting a long time to utter those words. Well, time to get back to business, right? Not so fast. As our series on SEC examinations has detailed, this is a long process. And if your firm received
Maintaining Effective Access Rights and Controls in Your Organization
You probably don’t need to be convinced that information security is critically important. But just in case you do, you should know that the U.S. Securities and Exchange Commission (SEC) continues to emphasize the importance it places on information security. In our last two posts, Marc and Craig began our discussion of the SEC’s Division
ESG Investing – Sustainable Compliance for Sustainable Investing
The market for investment products and services is very competitive. Consumers now look to their advisers to not only provide return on their investment but to do so in a way that is consistent with their personal ethos. To meet this demand, many investment advisers have turned to incorporating environmental, social, and governance (“ESG”) factors
Valuation and Fee Assessment – What Your Compliance Program Needs to Have
Over 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
A New Approach to Advertising – the SEC Revises Investment Adviser Advertising Regulation
We interrupt our regularly scheduled programming to bring you this special update. Well, technically it’s the U.S. Securities and Exchange Commission’s (“SEC”) update and it pertains to the regulation of investment adviser advertising. On December 22, 2020, the SEC amended the current regulatory framework governing investment adviser advertising. In making these changes, the SEC incorporated
Soft Dollar Arrangements – What to Know
In our last post, Craig began our discussion of trading practices by examining an adviser’s duty to obtain best execution. This post continues our trading practice discussion with a focus on soft dollar arrangements.
Soft dollar arrangements generally arise when an adviser receives research or brokerage products or services from a broker-dealer in exchange
Registering your robo-advisory firm – where and how?
Before your robo-adviser can accept its first client, it must be registered. Like other investment advisers, robo-advisers have two possible initial registration pathways. They either register with the SEC or they register with the state(s) where they maintain a place of business. Due to the additional complexity associated with state registration, most robo-advisers seek to