Earlier this month, the California Department of Corporations announced proposed changes to rules regulating investment advisers registered in California. According to the release, the objective in proposing the amendments is to increase uniformity with the model rules suggested by the North American Securities Administrators Association (NASAA), rules already in effect in other states, and rules [...]
Posted by Bryan Hill
Thursday, August 30, 2007
In our series “Year-End Compliance Tips,” we are next focusing on investment advisor codes of ethics. The SEC and many state securities regulators require investment advisor firms to create and implement a code of ethics. All SEC firms must require all employees to read and agree to abide by the firm’s original code of ethics [...]
Posted by Bryan Hill
Wednesday, December 20, 2006
This is the third entry in a series of blogs RIA Compliance Consultants is posting concerning annual compliance requirements and end of year filings. While we are trying to touch upon the items that all advisor firms are required to complete, it is important that you refer to your regulatory authority to ensure you have [...]
In an earlier blog posting, we discussed the fact that investment advisor firms must determine their access persons and ensure appropriate procedures are implemented to review all access persons’ household accounts. In their efforts to meet this requirement, many advisor firms have been asking exactly which types of securities holdings and transactions need to be [...]
Regulators have been emphasizing the need for investment advisors to develop and maintain a culture of compliance. Of course, one of the best ways to implement a culture of compliance is for the firm to establish adequate training and continuing education programs. We recommend that advisor firms hold some form of compliance training or meetings [...]
Is your firm’s new Code of Ethics described in your ADV Part II? Does your ADV Part II allow clients to request a copy of the Code of Ethics? This is an item that some investment advisors have overlooked. The recently effective SEC Rule 204A-1 requires all SEC registered firms to include a summary of [...]
It’s likely that your firm has recently established an “access persons” list and received its first holding reports in order to comply with the recently effective SEC Rule 204A-1. However, is your firm actually supervising the reported transactions of the access persons and documenting such supervision? Under Rule 204A-1, SEC registered investment advisory firms are [...]
