Category Archives: Compliance Training
For many registered investment advisers, the task of determining ongoing compliance requirements can seem overwhelming. Carrying out an investment adviser’s ongoing compliance duties can be a very manageable process if the investment adviser is aware of its requirements and organizes and assigns responsibilities for the various compliance functions. A compliance calendar can be a valuable [...]
Posted by Bryan Hill
Tuesday, November 29, 2011
A recent FINRA enforcement action highlights the need for broker dealers and investment advisers to implement policies and procedures for social media use. FINRA alleged the registered representative created websites related to her firm without obtaining firm approval, on several occasions she falsely stated online that she was not affiliated with any broker dealer, and [...]
Social media sites such as Facebook, Twitter, and LinkedIn can be useful business tools for investment advisers. However, there are several compliance issues that social media sites present. While the US Securities and Exchange Commission (“SEC”) has not released any specific rules or guidance on the topic, there are several existing rules that investment advisers [...]
Posted by Bryan Hill
Tuesday, September 27, 2011
With the upcoming regulatory switch of mid-sized investment advisers from the U.S. Securities and Exchange Commission (“SEC”) to state securities regulators and Congress considering whether to authorize a self-regulatory organization (“SRO”) for investment advisers, we believe that the frequency of investment adviser examinations is going to rise. During a regulatory exam, your investment adviser firm [...]
Posted by Bryan Hill
Tuesday, September 13, 2011
The best approach for an investment adviser firm to prepare for a regulatory examination begins with ongoing compliance training. A report released by the U.S. Securities and Exchange Commission (“SEC) on February 2011, stated “In most cases, the staff considers the quality of the [investment adviser’s] compliance systems and its internal control environment when determining [...]
Posted by Bryan Hill
Friday, September 9, 2011
Your investment adviser’s chief compliance officer (“CCO”) must be knowledgeable regarding the Investment Advisers Act of 1940, competent in regard to administering your compliance program and empowered to enforce compliance with your policies and procedures. Your investment adviser’s CCO is responsible for administering your investment advisers’ policies and procedures. This does not necessarily mean that [...]
When establishing a compliance program, an investment adviser is required to review and monitor the personal securities transactions by “access persons” in order to prevent inappropriate trading. In order to supervise personal securities transactions, the first question is determining which individuals are access persons. The U.S. Securities and Exchange Commission (“SEC”) defines an “access person” [...]
The U.S. Securities and Exchange Commission (SEC) has been examining certain recently registered investment advisers by conducting limited scope, one-day examinations. According to the SEC’s cover letter sent in advance of these audits, “the purpose of these examinations is to assess and discuss important risk areas presented be the registered investment advisers’ operations and the [...]
If your firm is registered with the SEC, RIA Compliance Consultants wants you to be aware that the Investment Advisers Act of 1940 provides state regulators authority over federally registered investment advisors and their employees, albeit on a limited scope. Many SEC firms believe that because they are not registered with a state regulator, they [...]
Our next installment of the “Year-End Compliance Tips” series is a reminder to advisors about compliance training. This time of year is a great time to hold compliance training for all employees and representatives. This is because many firms implement new policies or advisory programs set to take effect at the beginning of the year. [...]
Posted by Bryan Hill
Wednesday, December 20, 2006
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