Category Archives: Uncategorized
 

Will Your Investment Adviser’s Use of an Outsourced CCO Survive Regulatory Scrutiny?

January 11, 2022

Although many investment adviser firms desire to outsource the chief compliance officer role to an unaffiliated third-party independent contractor (“Outsourced CCO”), such an arrangement will be scrutinized and could be  challenged by the securities regulator as a violation Rule 206(4)-7 or equivalent rule of the state securities regulator depending upon the facts and circumstances.

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Failure to Properly Renew Registration May Result in Adverse Consequences for Investment Advisers

October 29, 2021

Investment adviser firms and investment adviser representatives must maintain active registrations and/or notice filing statuses with applicable jurisdictions/states. Unless properly renewed, all investment adviser firm and investment adviser representative licensing approvals expire December 31 each calendar year. To ensure that investment adviser firms and their investment adviser representatives are properly licensed in all necessary jurisdictions for 2022, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.

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New Guidance on New York IAR Registration

July 14, 2021

The Investor Protection Bureau of the State of New York’s Office of Attorney General recently issued new guidance clarifying the state’s new process for registering investment adviser representatives (“IARs”). This guidance will be of particular interest to new and existing investment adviser representatives seeking registration in New York. Existing investment adviser representatives have until December 2, 2021 to comply with the registration requirement but must submit a Form U4 requesting investment adviser representative registration in New York on or before August 31, 2021.

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RIA Phishing Email Alert – Posing as FINRA

June 09, 2021

Recently, several of our RIA clients have received suspicious emails claiming to be from FINRA. The suspicious emails used the subject line “New FINRA Request – (Firm Name),” and came from an email address with the domain, “@gateway-finra.org” Below is a screenshot of one of these suspicious emails.

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