U.S. Compliance Consultants, LLC
U.S. Compliance Consultants, LLC
Blog Post

New blog articles detected.

  • SEC Issues Risk Alert About Performance Advertising
    In a Risk Alert issued today, the SEC’s Office of Compliance Inspections and Examinations has provided a list of compliance issues relating to Rule 206(4)-1 (the “Advertising Rule”). These compliance issues were most frequently identified in deficiency letters recently sent … Continued The post SEC Issues Risk Alert About Performance Advertising appeared first on US Compliance Consultants.
U.S. Compliance Consultants, LLC
U.S. Compliance Consultants, LLC
Blog Post

New blog articles detected.

  • For 2 Advisers Cherry Picking Season is Over!
    In two separate administrative actions, the SEC barred two state-registered investment adviser for allocating trades in client accounts in a manner that disadvantaged their respective clients. The SEC also fined the heck out of them. In the Matter of Jeremy … Continued The post For 2 Advisers Cherry Picking Season is Over! appeared first on US Compliance Consultants.
U.S. Compliance Consultants, LLC
U.S. Compliance Consultants, LLC
Blog Post

New blog articles detected.

  • Outsourced CCO Fined $30,000 for ADV Misstatements
    The position of chief compliance officer of a registered investment adviser has always carried with it the risk of personal liability. Being an outsourced CCO is even more perilous. After all, if you are not on-site at the advisory firm … Continued The post Outsourced CCO Fined $30,000 for ADV Misstatements appeared first on US Compliance Consultants.
U.S. Compliance Consultants, LLC
U.S. Compliance Consultants, LLC
Blog Post

New blog articles detected.

  • Observations From SEC Cybersecurity Examinations
    Cybersecurity is all the rage and appropriately, the SEC recently concluded its second cybersecurity exam initiative of investment advisers, broker-dealers and investment companies. The examinations focused on the firms’ written policies and procedures regarding cybersecurity, including validating and testing that … Continued The post Observations From SEC Cybersecurity Examinations appeared first...
U.S. Compliance Consultants, LLC
U.S. Compliance Consultants, LLC
Blog Post

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
U.S. Compliance Consultants, LLC
Blog Post

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
U.S. Compliance Consultants, LLC
Blog Post

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
U.S. Compliance Consultants, LLC
Blog Post

New blog articles detected.

  • SEC Issues Guidance Re: Inadvertent Custody
    Maybe there is something wrong with a rule that needs continual guidance? See the latest SEC Investment Management Guidance:  Inadvertent Custody: Advisory Contract Versus Custodial Contract Authority
U.S. Compliance Consultants, LLC
U.S. Compliance Consultants, LLC
Blog Post

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
U.S. Compliance Consultants, LLC
Blog Post

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...

Out-Market Your Competitors?

Get complete competitive insights on over 2.2 million companies to drive your marketing strategy.

Create Free Account Log in

By signing up, you agree to the Terms of Service and Privacy Policy.

Out-Market Your Competitors

Get complete competitive insights on over 2.2 million companies to drive your marketing strategy.

Create Free Account

Already a user?  Log in

By signing up, you agree to the Terms of Service and Privacy Policy.