Mississippi is the first state to adopt the Model Rule on Investment Adviser Representative Continuing Education (“Model Rule”) published by the North American Securities Administrators Association (“NASAA”) in 2020. Adopted without substantive changes, Mississippi’s new IAR CE rule closely tracks the Model Rule which will simplify compliance for investment adviser representatives registered in multiple states. As states continue to adopt the IAR CE Model Rule, NASAA will update its list of member states that are adopting the Model Rule.
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SEC Risk Alert – Wrap Fee Programs
July 26, 2021
SEC Risk Alert on Use of Wrap Fee Accounts by Investment Advisers
On July 21, 2021, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (“SEC”) released a Risk Alert about its assessment of investment adviser firms associated with wrap fee programs.
The SEC identified multiple areas where the investment advisers examined were deficient in their policies, procedures, and practices related to wrap fee programs, and further noted a range of industry practices that investment advisers might consider adopting to meet their fiduciary duty when recommending and managing wrap fee programs.
