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Tuesday, June 12, 2012

Constitutionality of State Securities Regulators Reporting to Investment Adviser SRO

H.R. 4624, the Investment Adviser Oversight Act of 2012, (“Investment Adviser Oversight Act”) proposes creating a self-regulatory organization (“SRO”) for investment advisers. Currently, the U.S. Securities and Exchange Commission (“SEC”) has primary oversight of federally registered investment advisers and state securities regulators have primary oversight of state-registered investment advisers. As a result of the Dodd–Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), state securities regulators have begun serving as the primary regulator for investment advisers with up to $100 million of assets under management. Those investment advisers with more than $100 million are regulated primarily by the SEC. The Investment Adviser Oversight Act, if passed, creates an SRO for all investment advisers to report to, including those at the state level. H.R. 4624 as it stands now would also require state securities regulators to report to an investment adviser SRO annually to make sure that the states are meeting standards.

Some commentators believe that the proposed Investment Adviser Oversight Act infringes upon the states’ sovereign rights to govern. The U.S. Constitution sets out the powers of Congress, the limits on Congress, and the limits on the states. The 10th Amendment provides that powers not granted to the federal government and not prohibited by the Constitution belong to the states. A North American Securities Administrators Association (“NASAA”) representative recently testified before the Committee on Financial Services of the U.S. House of Representatives (“Financial Services Committee”) that “states are sovereign, independent entities, and should not be subordinated to a private, industry-funded corporation. Such a regulatory structure would compromise the independence and flexibility that are essential to effective state regulation.” Furthermore, he said “states, like the federal government, are statutory regulators and accordingly should not be subordinated to an industry self-regulator.” His full testimony is available online.

The representative from NASAA makes an interesting point. The Investment Adviser Oversight Act would require an annual conference for state securities regulators to report to an investment adviser SRO and for the SRO to evaluate each state’s regulatory performance. In essence, it would require state governments to report to a private corporation, which up to this point is unprecedented. There is precedent in Congress delegating power to agencies of the Executive Branch to regulate and to delegation of power for SROs to regulate within an industry. However, this is different. This is forcing a government entity to report to a private entity.

During the testimony in front of the Financial Services Committee, members of the panel referenced a document called the CATO brief. According to its website, “CATO is a public policy research organization dedicated to the principles of individual liberty, limited government, free markets and peace.” The brief drawn up by CATO argues among other things that “delegation of power to private actors should be construed narrowly and reviewed with an eye toward ensuring that exercises of regulatory authority remain rooted in the enumerated powers of the Constitution.” The brief was written arguing that the Financial Industry Regulatory Authority (“FINRA”) and more generally SROS must be amenable for private suit. In the brief, CATO points out that SROs are considered by some to be the same as agencies and other regulatory bodies but that SROs and specifically FINRA operates as a private actor. “Despite their role as front-line regulators, many (SROs) are “looking for ways to shed their self-regulatory responsibilities and join the ranks of their erstwhile members as for-profit competitors.” The brief also argues that there has been a lack of government oversight over FINRA and this lack of oversight led to policy failures within FINRA. CATO cites lax regulation and biased arbitration as examples of FINRA policy failures.

The argument in the CATO brief goes back to the concerns of the NASAA. The state securities regulators believe that they should not be subordinated to a private entity and that SROs are susceptible to abuse of power and ulterior motives.

Monday, June 11, 2012

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Friday, June 8, 2012

For Purposes of 408(b)(2), What is an ERISA Covered Plan?

Service providers are required to provide the new 408(b)(2) disclosures to any ERISA covered plan for which they provide services.  However, what exactly is an ERISA covered plan?

Under the ERISA 408(b)(2) disclosure requirement, a ‘covered plan’ means an employee pension benefit plan or a pension plan.  Section 1102(2) of the Employee Retirement Income Security Act of 1974 (“ERISA”) defines the terms “employee pension benefit plan” and “pension plan” as any plan that “(i) provides retirement income to employees, or (ii) results in a deferral of income by employees…regardless of the method of calculating the contribution made to the plan, the method of calculating the benefits under the plan or the method of distributing benefits from the plan.”  In plain English terms this means that the 408(b)(2) requirements apply to any employee benefit plan whether the benefits are defined or the employee is responsible for making contributions.

However, the new ERISA 408(b)(2) regulation does contain exceptions to the definition of “covered plan”.  Specifically, the 408(b)(2) regulations do not apply to any plan, including a pension plan, under which no employees are participants in the plan.  Further, the 408(b)(2) rule release provides some specific examples of what is not considered a covered plan for purposes of the 408(b)(2) disclosure requirement.  The following are not required to receive the 408(b)(2) disclosures:

a)      a “simplified employee pension”;

b)      a “simple retirement account”;

c)      an individual retirement account (IRA) or an individual retirement account annuity;

d)     a 403(b) plan that consists exclusively of “frozen” contracts or accounts;

e)      health savings accounts;

f)       a Keogh or “HR-10” plan that provides benefits only to a business owner and his or her spouse or only to partners in a partnership and to his or her spouse with respect to the partnership.

If you have any questions as to whether your investment adviser is required to provide the 408(b)(2) disclosures to your retirement plan clients, one of our consultants would be happy to assist you.  If you are already a client of RIA Compliance Consultants, please contact your consultant. If you are a new client, click here to schedule a time to speak with one of our consultants.

Thursday, June 7, 2012

Investment Advisers Are Encouraged to Review Their Websites for Marketing Violations

Investment adviser marketing materials and advertisements are regulated by Rule 206(4)-1 of the Investment Advisers Act of 1940 (“Investment Advisers Act”) and similar state regulations. Under Rule 206(4)-1, an SEC registered investment adviser’s website is considered a form of advertisement under the following circumstances:

“For the purposes of this section the term advertisement shall include any notice, circular, letter or other written communication addressed to more than one person, or any notice or other announcement in any publication or by radio or television, which offers (1) any analysis, report, or publication concerning securities, or which is to be used in making any determination as to when to buy or sell any security, or which security to buy or sell, or (2) any graph, chart, formula, or other device to be used in making any determination as to when to buy or sell any security, or which security to buy or sell, or (3) any other investment advisory service with regard to securities.”

Rule 206(4)-1 generally prohibits an SEC registered investment adviser from using client testimonials and the use of past specific recommendations and seeks to prevent the use of false or misleading information. Investment advisers should take care when reviewing the content of their websites as the information contained within the content can easily become considered false or misleading, especially if the content becomes outdated or contains unverifiable statements.

The following are examples of common website deficiencies that investment advisers should take care to avoid:

  • Failure to clearly indicate that the firm is a registered investment adviser;
  • If the investment adviser has multiple entities, failure to clarify what services are offered by the particular entity;
  • Failure to include website disclosure language;
  • Using misleading statements;
  • Using testimonials;
  • Displaying outdated information;
  • Overstating qualifications or experience; and
  • Using language that may be construed as a guarantee.

In order to avoid regulatory violations, an investment adviser should have its chief compliance officer (“CCO”) or compliance department review and approve all website content before it is posted. Additionally, an investment adviser’s CCO is encouraged to frequently monitor and review the content of the investment adviser’s website. Likewise, it is essential that an investment adviser has written policies and procedures that require frequent website reviews as part of its on-going compliance program.

An investment adviser’s website can be a great marketing tool as long as it remains compliant with the regulations of the SEC or state securities regulators. Simply, an investment adviser should remember its fiduciary role and act in accordance with such fiduciary obligations which extend to advertising and marketing materials.

On June 14, 2012 at 12:00pm CDT, RIA Compliance Consultants is hosting a webinar designed to educate investment advisers on the importance of approving marketing materials used by investment advisers. To register for this upcoming webinar, “Approving Marketing Materials,” please click here. If your investment adviser would like to speak with RIA Compliance Consultants to discuss ways in which we may further assist your investment adviser with its continuous on-going compliance requirements, contact your consultant if you are an existing client or new clients can click here to schedule a time to speak to one of our senior compliance consultants.

Wednesday, June 6, 2012

Highlights from the Financial Services Committee’s Hearing on the SRO Bill for Investment Advisers

This morning the Committee on Financial Services of the U.S. House of Representatives (“Financial Services Committee”) held a hearing on the Investment Adviser Oversight Act of 2012 (“Investment Adviser Oversight Act”). The Investment Adviser Oversight Act proposes the creation of a self-regulatory organization (“SRO”) for investment advisers. The panel of witnesses for the hearing consisted of representatives from the Financial Services Institute (“FSI”), the National Association of Insurance and Financial Advisors (“NAIFA”), the Securities Industry and Financial Markets Association (“SIFMA”), the Financial Industry Regulatory Authority (“FINRA”), the North American Securities Administrators Association (NASAA), and the Investment Adviser Association (“IAA”).

Representative Bachus (R – AL), Chairman of the Financial Services Committee and co-sponsor of the bill opened the hearing by declaring “The investing public deserves more robust oversight of these professionals to whom they have entrusted their hard-earned money… This bipartisan bill helps close what everyone agrees is a glaring regulatory gap – a gap that puts the average American investor at risk and undermines investor confidence.” Co-sponsor Rep. Carolyn McCarthy (D – NY) said she would actually prefer to use the U.S. Securities and Exchange Commission (“SEC”) but “it’s not going to receive the funding it needs and this is the best option.”

Ranking member of the Financial Services Committee Rep. Barney Frank (D – MA) acknowledged the need to do a better job of regulating. He also expressed his opposition to the bill. “What we need to do is first fully fund the SEC. Give enough resources to the SEC to do its job.”

Dale Brown, President of FSI said FSI endorsed the bill and explained that FINRA is the best choice to be the SRO for investment advisers because FSI members have a good working relationship with FINRA and utilizing the SRO would not burden taxpayers. Brown testified that the Investment Adviser Oversight Act would “greatly enhance investor protection by replacing the current patchwork of regulation with a set of uniform examination and enforcement standards.”

Thomas Currey, former President of NAIFA, testified that NAIFA supports the bill as well. “From NAIFA’s perspective, the Investment Adviser Oversight Act is the most sound and practical approach. Allowing FINRA to serve as the SRO for investment advisers is simple common sense.”

The representative for SIFMA, Chet Helck, testified that “SIFMA’s support for a so-called self-regulatory organization for retail advisers is premised on the recognition that broker-dealers provide some of the same services as investment advisers – including providing personalized investment advice to individual clients. We believe that when broker-dealers and investment advisers provide the same service, they should be held to the same standard.” Later when questioned, Helck said he believes the bill does not go far enough in regulating investment advisers but that it is a good start.

Richard Ketchum of FINRA noted that this idea of an SRO for investment advisers is not new, “in 1963 the SEC proposed an SRO for investment advisers.” Ketchum also testified that those investment advisers who are state-registered and compliant would have extremely low fees as a member of the SRO (assuming that FINRA would be the SRO). He believes the bill fills the gap in the oversight of investment advisers and that FINRA is positioned to fill the role as SRO.

Two panel members that testified in strong opposition of the bill and FINRA as SRO were John Morgan and David Tittsworth.  Morgan testified that NASAA strongly opposes the Investment Adviser Oversight Act and that requiring state-registered investment advisers to join an SRO is unnecessary and burdensome regulation. The bill “embraces a ‘one size fits all’ approach. It will require some federally registered investment advisers and most state registered investment advisers to become members of an SRO, pay membership fees to the SRO, comply with its rules, and be subject to inspection by the SRO—regardless of whether the firm has clients in more than one state or conducts business in a way that has any demonstrable effect on national markets.” The bill “creates regulatory fatigue” and “many investment advisers will simply close their doors” if the SRO bill passes. In response to a question about low member ship fees for state registered investment advisers Morgan responded, “Membership fees are just part of the cost, there are additional fees such as ongoing compliance costs.”

Tittsworth testified on behalf of the IAA that the Investment Adviser Oversight Act “unfairly targets small businesses.”  The IAA believes that “because of exemptions in the bill, smaller advisers are singled out for additional regulation and costs. The substantial costs and bureaucracy of an additional, unnecessary layer of SRO regulation and oversight of advisory firms would have a significant adverse impact on small businesses and job creation.” The IAA advocates continued SEC oversight and assessing user fees on all SEC registered investment advisers. He said outsourcing government oversight to an SRO is not the best method and cited reports from the U.S. Chamber of Commerce, the U.S. Government Accountability Office (“GAO”), and the Boston Consulting Group (“BCG”) that “identified deficiencies in the SRO model.”

Wednesday, June 6, 2012

Results of Massachusetts Securities Division Survey Finds Heavy Toll if New Investment Adviser SRO Adopted

 The Massachusetts Securities Division (“Division”) recently conducted a survey to determine the possible impact of the proposed Investment Adviser Oversight Act of 2012 (“Investment Adviser Oversight Act”) which was introduced in the United States House of Representatives by Representative Spencer Bachus (R – AL) Chairman of the Financial Services Committee. If enacted the Investment Adviser Oversight Act would create a self-regulatory organization (“SRO”) for investment advisers. The Massachusetts Securities Division’s survey was sent out to 649 investment advisers, and the Division received 353 surveys back. Responses came from a wide spectrum of investment advisers in the state.

 According to the report filed by the Massachusetts Securities Division, the survey reflects the “demographic of the typical Massachusetts registered investment adviser.” Most investment advisers reported less than $30 million in assets under management, “95% had fewer than 5 employees, and about half generate revenues less than $50,000 per year.”

The results of the survey indicate that investment advisers in Massachusetts strongly oppose the institution of an SRO. Results revealed that “98% of the investment advisers believe the Investment Adviser Oversight Act would have a negative financial impact on their firm because of fees incurred joining the SRO”. Investment advisers disclosed that they would be less likely to hire new employees and retain current employees if they have to pay the additional fees.

The most telling number of the survey was that 41% of the investment advisers said the fees associated with joining the SRO could put them out of business (assuming the average cost per member of an SRO for investment advisers to be $10,000-$35,000 per year which is much higher than the $300 a year to register with the state of Massachusetts).

Tuesday, June 5, 2012

GAO Report Finds SEC Oversight of FIRA Lacking & Critics Use Report Against FINRA as Potential Investment Adviser SRO

The U.S. Government Accountability Office (“GAO”) recently released a report on the U.S. Securities and Exchange Commission’s (“SEC”) oversight of the Financial Industry Regulatory Authority (“FINRA”). The report examined “how the SEC conducted oversight of FINRA and how it plans to enhance oversight in the future.”

The SEC is responsible for oversight of financial self-regulatory organizations (“SRO”). The SEC supervises FINRA by conducting inspections and reviewing proposed SRO rules. Section 964 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) required GAO to review SEC oversight of FINRA. Specifically, Section 964 identified the need to review “examinations, effectiveness of FINRA rules, arbitration services, advertising regulation, governance, executive compensation, cooperation with state securities regulators, funding, and policies regarding former FINRA employees.” To conduct the review, GAO “reviewed and assessed the SEC’s documentation, procedures and guidance for inspections of FINRA.”

After its review GAO found SEC oversight of FINRA deficient in several areas. The investigation indicated the SEC failed to maintain oversight at the same level for all FINRA programs. Areas with strong SEC oversight include FINRA regulatory programs such as examinations, surveillance, and advertising. GAO’s report found oversight of FINRA executive compensation, cooperation with state securities regulators, and transparency of governance to be nonexistent. According to the report, the lack of SEC oversight in these areas was a result of “competing priorities” and a lack of sufficient resources.  The report also criticized FINRA’s lack of retrospective reviews of its rules.  “By not conducting these reviews, FINRA may be missing on an opportunity to assess whether its rules are achieving their intended purpose and take appropriate action when necessary.” Information found in the report fueled the fires for those in opposition to FINRA becoming the SRO for investment advisers.

The Project On Government Oversight (“POGO”) recently wrote a letter to leaders of the Committee on Financial Services of the U.S. House of Representatives (“Financial Services Committee”) regarding the Investment Adviser Oversight Act of 2012 (“Investment Adviser Oversight Act”) citing this GAO report. The letter raised concerns over the creation of a new SRO for investment advisers and concerns that FINRA may be selected as that SRO. POGO believes there is a conflict of interest with SROs and that FINRA lacks transparency and accountability. Furthermore, the group believes government oversight is the best way to regulate investment advisers. The letter recommends that the Financial Services Committee reject the Investment Adviser Oversight Act and instead provide additional funding for the SEC to “carry out its important regulatory duties on its own without reliance on SROs.”

Monday, June 4, 2012

Hearing for Investment Adviser SRO Bill Scheduled for June 6

A hearing for the controversial Self-Regulatory Organization (“SRO”) bill submitted by Representative Spencer Bachus(R – AL), Chairman of the U.S. House Financial Services Committee, is scheduled to be heard on June 6th at 10 a.m. EST.

The SRO bill was introduced by Rep. Bachus and Rep. Carolyn McCarthy (D – NY) in April 2012. Officially titled as the Investment Adviser Oversight Act of 2012, the bill would amend the Investment Advisers Act of 1940 to include SROs for all investment advisers.  Under the bill, every investment adviser currently registered with the U.S. Securities and Exchange Commission (“SEC”) or a state securities regulator would be required to register with a SRO.

Although the investment adviser SRO bill has bipartisan support, several representatives have voiced their opposition to the proposed legislation.  Recently, Rep. Maxine Waters (D – CA), the second highest ranking Democrat on the House Financial Services Committee, expressed her preference in an article written by Investment News that the SEC continue in its role overseeing investment advisers.  Moreover, Rep. Barney Frank (D – MA), the highest ranking Democrat on the House Financial Services Committee who has announced his retirement at the end of this term, also expressed his opposition to the bill earlier this year according to the article. Rep. Waters advocates more funding for the SEC so it can increase the frequency of adviser examinations. Currently, only about 9% of advisers are examined each year by the SEC while the number for broker-dealers who are examined by FINRA is 58%. Additional funding could be used by the SEC to hire staff to increase the number of examinations done each year.

Some investment advisers oppose the SRO bill because it would increase costs, potentially put many small firms out of business and create an “unnecessary” layer of regulation. State regulators also oppose the legislation. Jack Herstein, head of the North American Securities Administrators Association (“NASAA”), recently called the bill “overreaching” and said that “state registered investment advisers should be exempted from the bill. “

Two of the most popular custodians for investment advisers are coming out to oppose the bill. TD Ameritrade and Charles Schwab & Company issued statements opposing the legislation and provide information for investment advisers on their institutional websites on how to voice their disapproval with the legislation. A form letter opposing the bill is available for advisers on the TD Ameritrade Institutional website to print, fill out and send to their representatives. RIAbiz.com reported that Schwab executive Bernie Clark asked advisers to email him or tweet opposition to the bill.

While many within the investment adviser industry are speaking out against the bill, the Financial Services Institute (“FSI”), which represents independent broker-dealers and their reps, recently wrote a letter re-iterating its support of an SRO for investment advisers. In it, FSI cited a poll it conducted that showed 75% of its advisers supported an SRO for investment advisers. The opinion from FSI also supported FINRA as the best option for the SRO because the SEC is “fraught with problems.”

Stay up to date with RIA Compliance Consultants on news regarding this legislation.

Saturday, June 2, 2012

Self-Regulatory Organization for Independent Investment Advisers Created by Law Professor and Students

The battle to add a Self-Regulatory Organization (SRO) for investment advisers is getting help from an unlikely source: the University of Mississippi Business Law Society. Students, with help from their professor, Mercer Bullard, started the Self-Regulatory Organization for Independent Investment Advisers (SROIIA). Students formed the organization to provide investment advisers an SRO tailored to their industry. The mission statement, as found on the organization’s website SROIIA, says that the organization is “seeking to become the preferred SRO for independent investment advisers by promoting a bona fide fiduciary standard, improving regulatory efficiency, and adopting a partnership approach in its relationship with advisers.” The executive management team of SROIIA is led by former and current Mississippi law students as well as two professors from the university, including Bullard, on the advisory board.

Bullard has an extensive background in the securities industry. According to his profile on the University of Mississippi School of Law website, “he was formerly an Assistant Chief Counsel at the Securities and Exchange Commission, he currently serves on the Securities and Exchange Commission’s Investment Advisory Committee and the Public Policy Council of the Certified Financial Planner Board of Standards and has litigated standing issues against the SEC, successfully challenged an SEC exemptive order, and submitted amicus briefs in cases involving an SEC rulemaking on broker regulation.”

“The recent Bachus-McCarthy Bill, and its specific provisions, confirms that the work we have been doing over the past few months has been in line with that which will be expected of an NIAA [National Investment Adviser Association]. Our progress to date has paralleled that which will be required of an NIAA – including registration requirements, rules and regulations, and governance and enforcement frameworks – with the additional features of being tailored to the desires of investment advisers and the heightened protections that today’s investors need…and we will continue in this direction,” said Timothy J. Collins, SROIIA’s co-Chief Executive Officer. Work done to tailor the SRO to the industry includes a survey distributed to investment advisers. The survey provided the SROIIA staff with feedback on what type of SRO investment advisors are willing to work with. The consensus of the survey was that investment advisers want to avoid working with FINRA but want an SRO that holds its members to a higher fiduciary standard.

Friday, June 1, 2012

SEC Investment Advisors: Time for a Final AUM Calculation

With the deadline for “the Switch” approaching, investment advisors that are currently registered with the U.S. Securities and Exchange Commission (“SEC”) should conduct one final calculation of their assets under management (“AUM”) to ensure that their investment advisor remains eligible for SEC registration.

Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act investment advisors with between $25 million and $100 million of regulatory assets under management are required to switch from the SEC to state registration.   Specifically, if an investment advisor that is currently SEC registered does not have $90 million in AUM then they are required to become registered with the appropriate state(s) and withdraw their SEC registration by filing a Form ADV-W by no later than June 28, 2012.  After June 28, the SEC will cancel the registration of investment advisors that are no longer eligible to remain registered with the SEC.  After this June 28th deadline, if an investment advisor that is no longer eligible for SEC registration has not registered with the appropriate states, the investment advisor will not be able to conduct business until its registration is approved.

If you have questions about how to calculate your assets under management, the SEC has provided detailed guidance in their instructions for Form ADV Part 1A, Item 5.F. The SEC uses a multi-level test to determine what investment advisory client assets should be reported as assets under management.  For a detailed discussion about this multi-level test, click here.

RIA Compliance Consultants can assist you with switching from SEC to state registration.  If you are an existing client of RIA Compliance Consultants interested in discussing how we can assist your investment advisor, please contact your consultant. If you are a new client that would like to speak with us regarding the services we can provide, please click here to schedule a time to speak with one of our consultants.


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* RIA Compliance Consultants, Inc. ("RCC") is not a law firm and does not provide legal services. A compliance consulting relationship with RCC is not provided those legal and professional protections that normally exist under an attorney-client relationship. For more information, please visit our Disclosures webpage.

The determination to use a third-party compliance services provider is an important decision and should not be based solely upon advertisements or self-proclaimed expertise. A description or indication of limitation of our compliance services does not mean that an agency or board has certified RCC as a specialist or expert in investment advisor compliance. All potential clients are urged to make their own independent investigation and evaluation of RCC.

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