Internal Control Report Earlier this month, new requirements under SEC Rule 206(4)-2 of the Investment Advisers Act of 1940 went into effect. The most stringent (and expensive) of these requirements is the new internal control report rule. Investment advisers or their related persons that serve as qualified custodian for investment advisory client funds or securities [...]
Join us for our complimentary webinar, the “The Nuts & Bolts of Registering an Investment Advisor,” on Wednesday, April 21, 2010 at 12:00 p.m. Central. During this webinar, RIA Compliance Consultants will explain in detail the process and documents necessary for registering a firm as an investment advisor, the criteria for determining whether a firm [...]
Advertising continues to be one of the primary focus areas of the SEC during investment adviser examinations. More specifically, performance advertising is one of the more common deficiencies found during SEC examinations and one that needs effective compliance oversight. During examinations, the SEC is interested in whether investment advisers have effective policies and procedures to [...]
Although the U.S. Securities and Exchange Commission (“SEC”) does not currently have any specific rules associated with the giving or receiving gifts or political contributions by representatives affiliated with a federally registered investment adviser, the influencing of others through gifts and political contributions in the context of an investment advisory relationship creates a potential conflict [...]
The U.S. Securities and Exchange Commission (“SEC”) recently proposed new SEC Rule 206(4)-5 under the Investment Advisers Act of 1940. According to the SEC, the proposed rule is intended to curtail “pay to play” practices by registered investment advisers that seek to manage money for state and local governments. This SEC proposal relates to money [...]
Posted by Bryan Hill
Wednesday, October 7, 2009
Earlier this year, the U.S. Securities and Exchange Commission (“SEC”) proposed new requirements for registered investment advisor firms that have custody of clients funds and securities. According to current SEC Rule 206(4)-2, Custody or Possession of Funds of Securities of Clients, custody is defined as “holding, directly or indirectly, client funds or securities, or having [...]
Posted by Bryan Hill
Monday, September 21, 2009
The Investment Adviser Regulatory Policy and Review Project Group of the North American Securities Administrators Association (known as “NASAA” and essentially consisting of state securities regulators) recently solicited comments from the public on a proposed model rule regarding solicitors for registered investment advisors. The comment period ended in August and NASAA has not yet released [...]
Posted by Bryan Hill
Tuesday, September 8, 2009
