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Kentucky Adopts IAR Continuing Education Rule, Cybersecurity Requirements

April 26, 2022

On April 18, 2022, Kentucky announced that it had adopted Senate Bill (“SB”) 298, making it the newest state to adopt an investment adviser representative continuing education (“IAR CE”) requirement, joining Mississippi, Vermont, Maryland, Michigan, and Wisconsin. Along with Michigan and Wisconsin, Kentucky’s new rule will become effective January 1, 2023. For investment adviser representatives in Mississippi, Vermont, and Maryland, an IAR CE requirement is already in effect.

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Email Phishing Scam from a FINRA Imposter

April 25, 2022

It was brought recently to our attention that many of our investment adviser clients have received a suspicious email similar to the sample below. This email appears to be sent from the email domain: claims-finra.org and includes a subject line such as “Re: FINRA URGENT REQUEST FOR….”

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Maryland Adopts IAR Continuing Education Rule

December 27, 2021

On December 7, 2021, the Maryland Securities Division announced its new investment adviser representative continuing education requirement, joining Mississippi and Vermont to now require investment adviser representatives to complete investment adviser representative continuing education (“IAR CE”). Closely tracking the NASAA’s Model IAR CE Rule and effective for the 2022 calendar year, investment adviser representatives who are registered in Maryland must now complete twelve credit hours of IAR CE on an annual basis. Of those twelve credit hours, six must be completed in “Products and Practices” and six in “Ethics and Professional Responsibilities,” with at least three focusing specifically on ethics.

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Investment Advisers Should begin Preparing to Submit their Annual Form ADV Amendment

December 22, 2021

Annual Amendment ServiceInvestment Advisers’ Final Renewal Statements and reports will be available for viewing and printing on January 2, 2022. All registered investment advisers should download and review these reports; Final Renewal Statements will indicate if any additional fees are due and these payments are due by January 22, 2022. Additionally, investment advisers with a fiscal year end of December 31 are encouraged to begin preparing their required Form ADV annual updating amendments.

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Deadline for Receipt of Preliminary Renewal Statement Payments Quickly Approaching

December 02, 2021

The deadline for investment advisers to submit their Preliminary Renewal Statement payment is quickly approaching. FINRA must be in receipt of the full payment listed on the Preliminary Renewal Statement by December 13, 2021. Investment advisers with sufficient funds in their Flex-Funding Account to cover the Preliminary Renewal Statement payment will have funds automatically transferred beginning on December 13, 2021 to the Renewal Account to cover total renewal fees owed. Automatic transfers will be conducted every day after December 13, 2021 until the WEB CRD/IARD shuts down for year-end processing on December 27, 2021. Investment advisers that choose to mail in their payments are advised to do so now to avoid delays and to ensure funds are received by the deadline.

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