The U.S. Securities and Exchange Commission (“SEC”) recently finalized revisions to Rule 205-3 under the Investment Advisers Act of 1940, raising the net worth requirements for individuals who are charged performance fees. As we discussed earlier, the SEC increased the threshold requirements for “qualified clients” to account for inflation. Under the revised rule, in order [...]
Category Archives: Written Policies and Procedures
Broker Dealers and Investment Advisers Need to Have Policies and Procedures in Place for Social Media Use
A recent FINRA Action highlighted the need for broker dealers and investment advisers to implement policies and procedures for social media use. FINRA brought this action because the registered representative had created websites related to her firm without obtaining firm approval, on several occasions she falsely stated online that she was not affiliated with any [...]
