U.S. Compliance Consultants, LLC

U.S. Compliance Consultants, LLC

Category: Content
Type: Blog Article

Generated 5 days ago

New blog articles detected

  • 7 Things Advisers Must Do To Avoid Custody

    A recent SEC No-Action Letter (Investment Adviser Association, February 21, 2017) clarified how an investment adviser can avoid having custody as a result of having a standing letter of instruction or other similar asset transfer authorization arrangement established by a client with a qualified custodian (SLOA). It is common for a client to grant its registered

U.S. Compliance Consultants, LLC

Category: Content
Type: Blog Article

Generated 1 week ago

New blog articles detected

  • 3 Ways to Reduce Potential SEC Penalties

    One day you might find yourself in a situation where you have discovered – through the normal operation of your compliance policies and procedures or through your compliance testing – that your advisory firm has come up short in some significant manner. Depending on the severity of the problem (i.e., level of client harm) your firm may

U.S. Compliance Consultants, LLC

Category: Content
Type: Blog Article

Generated 1 month ago

New blog articles detected

  • SEC Cybersecurity Exam Requests

    Cybersecurity seems to be all the rage with both SEC and state regulators. However, advisers have been flying blind as to what the regulators may actually request during a cybersecurity exam. Thanks to our contacts in the industry, we were able to obtain a list of cybersecurity-related information requested by the SEC during a recent exam of

U.S. Compliance Consultants, LLC

Category: Content
Type: Blog Article

Generated 2 months ago

U.S. Compliance Consultants, LLC

Category: Content
Type: Blog Article

Generated 2 months ago

New blog articles detected

  • 3 Most Typical Books & Records Rule Deficiencies

    Below are three typical examples of deficiencies or weaknesses with respect to the Books and Records Rule identified by the SEC staff: Did not maintain all required records. The SEC staff observed that certain advisers may not have maintained all the books and records required by the Books and Records Rule, such as trade records,

U.S. Compliance Consultants, LLC

Category: Content
Type: Blog Article

Generated 3 months ago

New blog articles detected

  • The 4 Most Typical Code of Ethics Violations

    As stated in the recent SEC Risk Alert, four typical code of ethics violations identified during examinations of investment advisers include: Access persons not identified. The SEC staff observed that certain advisers did not identify all of their access persons (e.g., certain employees, partners or directors) for purposes of reviewing personal securities transactions. Codes of ethics missing requ...

  • Top 3 Custody Deficiencies

    As stated in the recent SEC Risk Alert, the 3 most frequent custody issues identified in examinations of investment advisers are as follows: Advisers did not recognize that they may have custody due to online access to client accounts. An adviser’s online access to client accounts may meet the definition of custody when such access provides the adviser with the

  • Top 4 Regulatory Filing Deficiencies

    As stated in the recent SEC Risk Alert, the 4 most frequent regulatory filing issues identified in examinations of investment advisers are as follows: Inaccurate disclosures. The SEC staff observed that certain advisers made inaccurate disclosures on Form ADV Part 1A or in Form ADV Part 2A brochures, such as inaccurately reporting custody information, regulatory assets

  • Top 4 Compliance Program Deficiencies

    As stated in the recent SEC Risk Alert, the 4 most frequent compliance issues identified in examinations of investment advisers are as follows: Compliance manuals are not reasonably tailored to the adviser’s business practices. The staff noted that certain compliance programs did not take into account important individualized business practices such as the adviser’s particular

  • 5 Most Frequent Compliance Topics Identified in Investment Adviser Exams

    The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) identified the following five areas of compliance deficiencies or weaknesses frequently found during its staff’s examinations of SEC-registered investment advisers: (1) Rule 206(4)-7 (the “Compliance Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”);  (2) required regulatory filings; (3) Rule 206(4)-2 under th...

  • SEC 2017 Examination Priorities

    The SEC’s Office of Compliance Inspections and Examinations has published its examination priorities for 2017. The priorities focus on electronic investment advice, money market funds, and financial exploitation of senior investors. In addition, the priorities “reflect a continuing focus on protecting retail investors, including individuals investing for their retirement, and assessing market-wide...

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