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Tuesday, July 3, 2012

Due Diligence of Broker-Dealers Often Overlooked by Investment Advisers

Due diligence needs to be an important component for any investment adviser compliance program.  As we discussed earlier, due diligence should not be limited to recommending investments, but must also be employed when recommending or using third party service providers.  In our opinion, one of the most important, if not the most important, outside service provider decisions made by investment advisers are the selection of a recommended broker/dealer.  In fact, many investment advisers require clients to use a particular broker/dealer.  However, far too many investment advisers fail to perform adequate due diligence on this important selection.  We hear from many investment advisers that they fully understand broker/dealer best execution reviews are expected, but are not completed because of reasons such as (1) the broker/dealer they work with is large and reputable, (2) the investment adviser only selects mutual funds so best execution doesn’t matter or (3) the differences between broker/dealers are so slight that due diligence is unnecessary.  Because of these reasons and others such as time and cost constraints, broker/dealer best execution reviews and due diligence is a matter often neglected by investment advisers.

Regardless of how valid the reasons not to conduct broker/dealer due diligence may be, the fact is outside service provider due diligence and broker/dealer best execution are issues regulators take seriously and remain a focus during routine examinations.  Investment advisers need to implement a system to conduct due diligence reviews of any third party hired to work on behalf of the firm, including broker-dealers.  Investment advisers cannot simply rely on information provided by the broker-dealer. Before using or recommending a broker-dealer to clients, an investment adviser must conduct an independent due diligence investigation to ensure, among other things, clients receive best execution of transactions.

At a minimum, we recommend investment advisers conduct a background check of the broker/dealer via the Financial Industry Regulatory Authority (“FINRA”) Broker Check, review publicly available information about the broker/dealer available on the internet, review the range and quality of services available, and review the reliability in executing trades and keeping records. While there are no set rules as to what an investment adviser must do to satisfy due diligence obligations, the presence of any “red flags” must alert it to the need for further inquiry.  As a fiduciary, providing a thorough investigation of broker/dealers used or recommended to clients is necessary for investment advisers.

Investment advisers also have the duty to investigate and obtain best execution of client transactions. The U.S. Securities and Exchange Commission (“SEC”) has communicated that best execution is not necessarily determined by the lowest possible transaction cost. Investment advisers must systematically and periodically evaluate the best execution practices of their broker/dealers to ensure that services meet their standards. Some of the criteria an investment adviser should consider are:

  • Trading expertise;
  • Execution capabilities;
  • Access to underwritten offerings and secondary markets;
  • Reliability in executing trades and keeping records;
  • The number of primary markets that will be checked; and
  • Timeliness of trade execution

Investment advisers should conduct a due diligence review of broker/dealers and best-execution before approving a broker/dealer and going forward at least annually if not more frequently. To demonstrate its due diligence an investment adviser should retain records documenting both the process and results of its investigation.

To learn more about performing due diligence on broker-dealers and best execution of client transactions sign up for RIA Compliance Consultants’ upcoming webinar “Conducting Service Provider Compliance Due Diligence Reviews.”  The webinar will be held on July 12, 2012, at 12 p.m. CDT.  RIA Compliance Consultants can assist you with establishing policies and procedures for your broker/dealer due diligence review or performing your review.  If you are an existing client of RIA Compliance Consultants interested in discussing how we can assist your investment adviser, please contact your consultant. If you are a new client that would like to speak with us regarding the services we can provide, please contact us to schedule a time to speak with one of our consultants.

Thursday, June 28, 2012

The Importance of Conducting Service Provider Due Diligence Review for Investment Advisers

Many investment advisers choose to engage third-party service providers to perform a number of important services for their firm and their advisory clients.  There are third-party service providers offering a number of important services to investment advisers.  Some of the services include client and portfolio management software systems, marketing of advisory services, referring clients to the investment adviser, calculating investment valuations, proxy voting, financial reporting, and maintaining required books and records.  However, when a service provider is utilized, the investment adviser still retains its fiduciary responsibilities for the delegated services.  As a result, investment advisers should develop strong compliance policies and procedures for performing due diligence when selecting and retaining third-party service providers.

While most investment advisers understand the due diligence process as it relates to recommending investments, many investment advisers neglect or cut corners when performing the due diligence process of third-party service providers. Establishing these relationships that will ultimately affect a client requires an investment adviser to have a system in place to conduct reviews to determine that the relationships are in the best interest of the clients and are in compliance with investment adviser regulations.  In fact, regulators have issued deficiencies to investment advisers that have failed to establish adequate due diligence policies and procedures even when no harm has been done to a client.

Investment advisers need to have in place a system to conduct a due diligence review of any third-party hired to work on behalf of or provide services on behalf of the investment adviser or to provide services to clients based on the recommendations of the investment adviser.  In order to implement and enforce a due diligence process, investment advisers should develop written policies and procedures outlining their due diligence process. An investment adviser’s due diligence policies and procedures should be designed to ensure that each third-party is properly investigated before an agreement is signed and the third-party does work on behalf of the investment adviser. The policies and procedures developed relating to the due diligence process should include documenting and retaining records related to the due diligence review.  Documentation should include the information gathered during the review process and well as the findings and results of the review.  It is important to develop a strong paper trail regarding the due diligence process so that when faced with a regulatory exam or investigation the investment adviser can demonstrate that a reasonable investigation was conducted  prior to establishing a relationship with any third-party.

It is also important to keep in mind that the due diligence review process is not a one-time process completed only at the time the initial relationship is established.  Ongoing due diligence is crucial and its absence creates a critical weakness in an investment adviser’s compliance program. Depending on the type of relationship and the services being provided by the third-party, quarterly or annual reviews should be conducted to examine any possible material changes that may be made to the third-party’s business practices and to re-evaluate factors analyzed during the initial due diligence review of the third-party.

If you would like more information regarding an investment adviser’s fiduciary duty to perform due diligence on third-party service providers, RIA Compliance Consultants is hosting a webinar, “Conducting Service Provider Compliance Due Diligence,” on July 12, 2012, at 12:00pm CDT.   During this webinar, our consultants will provide advice on what items should be covered during an investment adviser’s initial due diligence review and as well as what should be included in follow-up reviews.  Click here to register for this webinar.

RIA Compliance Consultants can help your investment adviser develop policies and procedures to implement a third-party service provide due diligence process.  If you would like to discuss how RIA Compliance Consultants can assist you, contact your consultant if you are an existing client or click here to schedule a time to speak with one of our consultants if you have not previously worked with RIA Compliance Consultants.

Thursday, June 21, 2012

State Registered Investment Advisers Should Expect Increase in Examinations After the Switch

As we have discussed in a previous newsletter article, investment advisers switching registration from the U.S. Securities and Exchange Commission (“SEC”) to state securities regulators are likely to see an increase in examinations. According to the North American Securities Administrators Association (“NASAA“), “firms switching to state regulation for the first time can expect thorough inspections generally on a more frequent basis than they may have experienced before.”

The switch is a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). Under the law, investment advisers with between $25 and $100 million in assets under management are required to make the move to state regulation.  According to NASAA an estimated 3,200 investment adviser firms are making the switch.

Many investment advisers making the transition from federal to state registration may not have much experience with regulatory examinations. According to testimony earlier this year from SEC Chairman Mary Shapiro the SEC examined only about 8% of investment advisers in 2011.  She further testified that “about forty percent of registered investment advisers have never been examined.” State investment adviser examination numbers are drastically different.  John Morgan, Securities Commissioner for the State of Texas, recently testified that “a majority of states examine investment advisers at a rate that is on average at least once every four years.”

The testimony from these two securities regulators demonstrates a stark difference. Investment advisers making the switch from the SEC to state registration should familiarize themselves with state investment adviser regulations in preparation for the examinations.

All SEC registered investment advisers had until March 30, 2012, regardless of their firm’s fiscal year end, to file an amendment to their Form ADV Part 1 to report their reason for eligibility to remain SEC registered or to report that they are no longer eligible for SEC registration. If your investment adviser was subject to the filing requirements and has not filed, immediate action must be taken to comply.

All SEC registered investment advisers that report they are no longer eligible for SEC registration have until June 28, 2012, to file an ADV-W to withdraw their SEC registration. All SEC registered investment advisers that must withdraw their SEC registration and “switch” to the appropriate state securities registration will need to be approved by the appropriate state regulators no later than June 28, 2012.

Investment advisers switching to state registration need to make sure that their compliance programs are updated to comply with the applicable state investment adviser regulations.  RIA Compliance Consultants can help your firm update its compliance program or perform a mock regulatory review to test your firm’s readiness for a regulatory exam.  If you would like to discuss how RIA Compliance Consultants can assist you, please contact your consultant if you are an existing client or click here to schedule a time to speak with one of our consultants if you have not previously worked with RIA Compliance Consultants.

Monday, June 18, 2012

NAPFA Sounds Alarm Against H.R. 4624, the Investment Adviser Oversight Act of 2012

The National Association of Personal Financial Advisors (NAPFA) recently released a statement on the potential negative effects of H.R. 4624, the Investment Adviser Oversight Act of 2012, (Investment Adviser Oversight Act). NAPFA says this bill will “allow the foxes to run the henhouse.” NAPFA is alluding to the belief that if the bill is passed and a self-regulatory organization (SRO) is created for investment advisers, it will be the Financial Industry Regulatory Authority (FINRA).

NAPFA is sounding the alarm because NAPFA believes that if FINRA becomes the SRO for investment advisers it “would be allowed to obtain a stranglehold over advisors by charging huge annual registration fees, create a hornet’s nest of rules that would make sound advice by independent advisors nearly impossible to economically provide, and limit transparency and accountability.”

NAPFA lists eight ways that oversight by FINRA would hurt investment advisers and investors:

1. FINRA’s exorbitant operating expenses and bloated salaries make them more Wall Street than Main Street.

2. FINRA’s mandatory membership fees will put many independent financial advisors who offer advice to middle-class savers out of business.

3. The burden of making small business owners pay mandatory fees to fund FINRA salaries is unconscionable.

4. FINRA is not subject to Sunshine Laws and doesn’t have to hold open meetings.

5. FINRA is not subject to the Freedom of Information Act and is notoriously secret about their books and records.

6. FINRA is an organization run by Wall Street’s executives who, with a “wink and a nod,” purport to oversee their Wall Street colleagues. This is like ENRON overseeing CPAs, or drug companies overseeing your family physician.

7. FINRA has no experience working with financial advisors held to the high fiduciary standard.

8. FINRA acts like a government authority, but without government accountability.

NAPFA supports a properly funded U.S. Securities and Exchange Commission (SEC) as the best option for investment adviser oversight. According to NAPFA National Chair Susan John, CFP® it “is the best way to ensure investment advisers are truly working in the best interests of those they serve — with accountability and transparency.”

Thursday, June 14, 2012

Do the New ERISA 408(b)(2) Requirements Apply to Your Investment Adviser?

The new ERISA 408(b)(2) regulations, which were recently issued by the U.S. Department of Labor (“DOL”), place disclosure requirements on “service providers” to ERISA covered plans.  Specifically, a covered service provider is required to disclose in writing the services to be provided, the service provider’s fiduciary status to the Plan, and a description of all direct and indirect compensation received in connection with services provided to the Plan.  Service providers must provide these disclosure requirement to plan fiduciaries in order for a contract for plan services to be “reasonable” as required by ERISA section 408(b)(2).

So which investment advisers are considered “service providers” and thus required to make the 408(b)(2) disclosures?

Under the 408(b)(2) regulation, a covered service provider is any person who provides services to an ERISA covered plan, if the service provider expects to receive at least $1000 for the services provided.  This $1000 threshold applies over the life of the services to the plan and is not calculated on an annual basis.

Registered investment advisers are considered covered service providers when they provide services directly to retirement plans subject to ERISA.  The key determination to make is who does the investment adviser have an advisory relationship with?  Simply providing advisory services to an individual who is a participant in an ERISA covered retirement plan does not subject an investment adviser to 408(b)(2).  On the other hand, if an investment adviser has an advisory relationship with a retirement plan and has entered into an agreement directly with that plan, then they are likely subject to 408(b)(2).

RIA Compliance Consultants is available to help investment advisers meet their 408(b)(2) disclosure requirements.  Our consultants can help your investment adviser prepare a 408(b)(2) disclosure guide which contains all of the required disclosures.  Additionally, we can review and update the service and fee descriptions in your Form ADV Part 2A Disclosure Brochure to ensure that your retirement plan services are adequately described and meet the 408(b)(2) requirements.

For more information about the services RIA Compliance Consultants can provide to assist you with meeting the 408(b)(2) requirements contact your consultant if you are an existing client or click here if you are a new client that would like to schedule a time for one of our consultants to call you to further discuss these services.

Wednesday, June 13, 2012

Investment Advisers Should Make Sure They Can Back-Up Statements and Claims Made in Advertising

Investment advisers must be cautious when it comes to the statements and claims used in advertising and marketing materials and this does not just pertain to performance claims. Investment advisers must avoid all statements or claims that are unsubstantiated or that cannot be proven with material facts.  Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) must ensure that all advertising and marketing material complies with Rule 206(4)-1 under the Investment Advisers Act of 1940 (“Investment Advisers Act”). Many state investment adviser regulations follow similar regulatory guidelines as those outlined in Rule 206(4)-1. Under SEC Rule 206(4)-1(a)(5), investment advisers are expressly prohibited from publishing, circulating and distributing any advertisement, “which contains any untrue statement of a material fact, or which is otherwise false or misleading

When preparing marketing materials, the investment adviser must make sure that the materials will not violate the prohibitions of Rule 206(4)-1 by containing any statements that are or can be interpreted as:

  • Promissory;
  • Misleading or false;
  • Contains untrue statements of material facts;
  • Implies inferences arising from the context;
  • Is overly sophisticated for the prospective or intended client.

The following are some examples of statements made in marketing materials that could be considered a violation of SEC Rule 206(4)-1:

Example 1: We take a unique approach to working with each of our clients.

Example 2: We are a premier “fee-only” financial planning and investment advisory firm.

Example 3: Our strategy is an innovative approach to financial success.

While many investment advisers may believe that the services they provide are unique or superior to those provided by other investment advisers, this could be extremely difficult if not impossible to prove.  Investment advisers making those types of claims must be able to provide substantiated evidence and factual data that would support the fact that when compared to all other investment advisers, their services are different or better than any other or even most other investment advisers.

Example 4: Call us today to find out how we can help you to achieve financial security in an uncertain economy.

Example 5: Begin your relationship with us today so that we can help you to secure your retirement while meeting your current obligations.

Example 6: By working with us, we will help you reach your financial dreams.

Investment advisers must also avoid statements that could be considered promissory in nature.  While most investment advisers view their role as someone to help its clients meet their financial goals and objectives, there is no guarantee that this can be done.  Therefore, statements should not be made in advertising and marketing materials by investment advisers to imply that they can. Generally, it is best for investment advisers to avoid terms that imply any form of guarantee in advertising and marketing. Additional safeguards may be to include disclosures within the advertising or marketing piece, such as “Every investment strategy has the potential for profit or loss.”

As part of an investment adviser’s on-going compliance program, an investment adviser’s chief compliance officer (CCO) or designated party should review an investment adviser’s advertisements and marketing materials before publication to ensure the materials are compliant with rules under the Investment Advisers Act or similar state regulations. An investment adviser should have in place written policies and procedures that include safeguards to ensure that and investment adviser’s advertising and marketing materials used remain compliance with the SEC or similar state regulations.

If your investment adviser would like additional information on approving marketing materials used by investment advisers, register for our upcoming webinar “Approving Marketing Materials.” This webinar will be hosted Thursday, June 14, 2012, at 12:00 pm CDT. To register for this webinar, click here. RIA Compliance Consultants can help your investment adviser with the review of advertising and marketing materials.  For more information on how RIA Compliance Consultants can assist you with your marketing review or other ongoing compliance needs,  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.

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.

 

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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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