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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.

Thursday, May 31, 2012

What Disclosures Are Required Under the New ERISA 408(b)(2) Regulation?

Under the new ERISA 408(b)(2) regulation a covered service provider is required to disclose in writing to the responsible plan fiduciary of an ERISA covered plan the services to be provided, its fiduciary status to the plan, and what compensation the service provider is to receive in connection with services provided.  The deadline for covered service providers to make these disclosures is July 1, 2012.

A covered service provider must provide the ERISA covered plan with a clear and understandable description of the services provided to the plan.  It is recommended that the disclosure identify which services are fiduciary and which are non-fiduciary.  Investment advisors who are covered service providers also must disclose their status as a fiduciary under ERISA section 3(21) and, if applicable, under section 3(38) as an “investment manager”.  Additionally, investment advisors who are covered service providers are required to disclose their investment advisor registration status, meaning the investment advisor is required to indicate whether the investment advisor is registered under the Investment Adviser’s Act of 1940 or under state law.

Regarding compensation, covered service providers must provide a description of all direct and indirect compensation received in connection with services provided to the ERISA covered plan.  This includes compensation received by an affiliate or subcontractor and any termination compensation that would be received.  Direct compensation is compensation received directly from the plan.  Indirect compensation is compensation received from any source other than the plan or plan sponsor.  Service providers must disclose how they will receive the compensation and, if the service provider will receive any indirect compensation, the service provider must disclose the relationship with the party providing the indirect compensation.  Additionally, in order to avoid a prohibited transaction, indirect compensation must be offset by the direct compensation received.

The July 1st deadline is fast approaching and RIA Compliance Consultants can help you meet the ERISA 408(b)(2) disclosure requirements.  Our consultants can help your investment advisor create a 408(b)(2) disclosure guide and review and update the service and fee descriptions in your Form ADV Part 2A Disclosure Brochure to ensure that your retirement plan services disclosure language meets the 408(b)(2) requirements.  To schedule a time with one of our consultants, click here.

Wednesday, May 30, 2012

Enforcement Actions Related to Advertising / Marketing for Investment Advisors

Marketing materials can be very helpful in attracting business for an investment advisor, but investment advisors should be aware of the regulatory requirements that apply to the use of marketing materials. Common issues with investment advisory marketing materials include using marketing materials that include testimonials (which investment advisors are generally prohibited from using); publishing past recommendations (without following the restrictions and disclosure requirements for publishing past recommendations); using language that makes promises or guarantees; and making untrue or misleading statements.

In one recent enforcement action published by the U.S. Securities and Exchange Commission (“SEC”) related to marketing materials, an investment advisor solicited investors with marketing materials that cited a successful investment history based on actual performance in managed accounts, the use of proprietary qualitative pricing models developed to invest in Exchange Traded Funds (ETFs), and the experience and knowledge of a particular investment advisor representative in managing the investments.

The SEC found the marketing materials contained material misrepresentations.  The SEC concluded that the performance information that the investment advisor had represented as performance based upon actual trades was, in fact, performance that was based upon back-tested hypothetical trades. The SEC also found the investment advisor had misrepresented the use of qualitative pricing models to make investment decisions, had misrepresented the investments actually made by the investment advisor, and had misrepresented which individual was actually managing the investments.

In another recent SEC enforcement action, an investment advisor created marketing materials to attract investors at conferences. The investment advisor distributed a brochure that included a 10-year track record that represented 11% average returns.  The investment advisor had not been in existence for 10 years, so not only was the timeframe represented inaccurate and misleading but the investment advisor had also failed to maintain accurate records to support the claimed returns.  The marketing information included additional misrepresentations, including a statement that the investment advisor had grown assets under management in another fund to $300 million when the named fund never had assets under management. Also, the marketing brochure indicated that the investment advisor conducted “thorough” due diligence in selecting managers; however, the SEC found that the investment advisor’s due diligence was “virtually nonexistent.”

For more information and guidance regarding the use of marketing materials for your investment advisor, join RIA Compliance Consultants on Thursday, June 14, 2012 at 12:00pm, CDT, as we present the webinar “Approving Marketing Materials.” During the webinar our consultants will be discussing examples of marketing materials that included prohibited promises, guarantees, and untrue statements. The consultants will also provide best practice recommendations and sample disclosures. If you would like to sign up for this webinar, click Approving Marketing Materials. RIA Compliance Consultants can provide assistance with reviewing your investment advisor’s marketing materials.  If you are an existing client of RIA Compliance Consultants, contact your consultant for more information.  If you are a new client interested in assistance, click here to schedule a time for one of our consultants to contact you to discuss your needs.

Thursday, May 24, 2012

ERISA 408(b)(2) Deadline Approaching

The final deadline for ERISA covered service providers to meet the 408(b)(2) disclosure requirements is July 1, 2012.  Failure to provide the required disclosures will result in a prohibited transaction under ERISA and the Internal Revenue Code.  For an investment advisor who is a service provider to an ERISA covered plan this would likely result in the investment advisor having to repay any compensation received after July 1, plus interest.  Additionally, the investment advisor could face a fine from the U.S. Department of Labor (“DOL”).

RIA Compliance Consultants can help your registered investment advisor create a 408(b)(2) disclosure guide that will satisfy all of the disclosure requirements of the new 408(b)(2) regulations.  Additionally, we can review and update the language in Items 4 and 5 of your Form ADV Part 2A Disclosure Brochure to ensure that you are properly disclosing your retirement plan services.

With the July 1st compliance deadline fast approaching, it is important not to delay!  If you are an existing client of RIA Compliance Consultants, please contact your consultant. If you are a new client, please click here to schedule a time to speak with one of our consultants.

Wednesday, May 23, 2012

Approving Marketing Materials for Investment Advisors

Under the anti-fraud provision of the Investment Advisers Act of 1940 (“Investment Advisers Act”) investment advisors registered with the U.S. Securities and Exchange Commission (“SEC”) must comply with the provision’s requirements concerning advertising and marketing materials. In efforts to prevent fraudulent, deceptive, or manipulative acts, your registered investment advisor should have in place strong supervisory and compliance policies and procedures designed to approve and monitor advertising and marketing materials. Federally registered investment advisors are routinely cited examination deficiencies for issuing non-compliant advertising materials. Much less, investment advisor firms have been cited for simply not establishing reasonably designed compliance policies and procedures for the creation, review and approval of advertising materials.

The importance of strong compliance controls for advertising and marketing materials is not limited to SEC registered investment advisor firms. In 2011, the North American Securities Administrators Association (“NASAA”) conducted an examination of 825 state-level advisers that revealed 3,543 deficiencies in 13 categories. Of the reported deficiencies, 21.6% of all investment advisers had at least one advertising deficiency. The result of the examination prompted NASAA to recommend best practices for investment advisers and specifically recommends investment advisers “review all advertisements, including websites and performance advertising, for accuracy.” (For a complete look at the examination results and best practices guidelines, click here.)

For many registered investment advisors, advertising materials can generate increased risk exposure. Using advertising claims that cannot be supported or proven, that are promissory, that are misleading or materially inaccurate must be avoided. Investment advisors should avoid specifically prohibited items, including: testimonials; the use of past specific recommendations that were profitable, unless the advisor includes a list of all recommendations made during the past year; a representation that any graph, chart, or formula can in and of itself be used to determine which securities to buy or sell; and advertisements stating that any report, analysis, or service is free, unless it really is free. An advertisement could include both a written publication (such as a website, blog newsletter or marketing brochure) as well as oral communications (such as an announcement made on radio or television).

All registered investment advisors should have detailed policies and procedures regarding advertising materials memorialized within their compliance program. It is advisable for investment advisors, as part of their on-going compliance program, to have in place policies requiring the pre-approval of all marketing materials. Investment advisors should be prepared for a thorough review of advertising materials during a regulatory examination.

For more information on the use of marketing materials for your investment advisor, join RIA Compliance Consultants on June 14, 2012, at 12:00 Central for our webinar, “Approving Marketing Materials.” During this webinar RIA Compliance Consultant will review SEC rules, no-action letters and enforcement actions related to marketing materials used by investment advisors. We will discuss examples of prohibited promises, guarantees and untrue statements. Our consultants will discuss best practices and sample disclosures related to client testimonials, client references, third-party rankings, top advisor lists, news article reprints and past investment recommendations. This webinar includes guidance about the regulatory considerations when an investment advisor uses a professional designation or social networking sites. Finally, our consultants will briefly explain the SEC’s requirements in order to show model or actual investment performance in advertising and marketing materials. To register for this webinar, please click here. This webinar is eligible for one credit hour towards the CFP professional designation continuing education requirements.


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