Category Archives: Compliance Training
 

Investment Adviser Compliance Training for 2020

February 20, 2020

On Thursday, February 20, 2020, RIA Compliance Consultants will is hosting an investment adviser compliance training webinar, “Common Questions for RCC Consultants.”  During this webinar our Senior Compliance Consultants will share the most common compliance questions they receive from investment adviser clients during the past calendar quarter. Our consultants will then discuss how they have addressed these questions and will offer best investment adviser compliance practices, tips and tricks.  Click here to purchase a seat for this compliance webinar.

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National Compliance Officer Day – Not All Heroes Wear Capes

September 27, 2019

Yesterday was the fourth annual Compliance Officer Day, a day to recognize and appreciate the work done by compliance professionals. RIA Compliance Consultants recognizes the 24/7 role demanded of compliance officers and personnel. We would like to thank you for your tireless work at building ethical cultures and helping your colleagues do the right thing. In appreciation to your dedication to compliance, we are offering a 25% discount on all of our Sample Compliance Forms and Compliance Training Webinars. Click here to shop on our online store. The 25% discount will be applied automatically at checkout.

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Repeat Compliance Program Deficiencies Result in SEC Enforcement Actions for Investment Advisers

November 05, 2013

On October 23, 2013, the U.S. Securities and Exchange Commission (“SEC”) issued a press release (Release No. 2013-226) indicating that it sanctioned three investment adviser firms “for repeatedly ignoring problems with their compliance programs.” The SEC’s enforcement actions are the result of the investment adviser firms each failing to effectively act upon previous warnings and correct compliance deficiencies that had been previously identified.  In the press release Andrew Bowden, director of the SEC’s National Examination Program, stated that, “After SEC examiners identified significant deficiencies, these firms did little or nothing to address them by the next examination. Firms must fix deficiencies identified by our examiners.”

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Investment Advisers Must Customize Their Compliance Programs

October 01, 2013

As we previously indicated, many investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) still have trouble meeting the requirements of Rule 206(4)-7 under the Investment Advisers Act of 1940 (“Investment Advisers Act”).  Pursuant to Rule 206(4)-7, investment advisers registered with the SEC are required to establish and maintain written policies and procedures reasonably designed to prevent violations of the Investment Advisers Act and the rules under the Investment Adviser Act. Most state securities regulations have similar requirements and many state registered investment advisers also have trouble complying with these requirements.

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A Refresher on the Requirements for Investment Advisers’ Written Policies and Procedures

September 25, 2013

Rule 206(4)–7 under the Investment Advisers Act of 1940 (“Investment Advisers Act”) became effective in February of 2004, yet for many investment advisers this continues to be a common area where regulatory deficiencies are found.  Under Rule 206(4)-7, investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) are required to adopt and implement written policies and procedures reasonably designed to prevent violations of the Investment Advisers Act. While Rule 206(4)-7 does not detail specific items that investment advisers must include in their policies and procedures, the final rule release indicates that investment advisers are required to “consider their fiduciary and regulatory obligations under the [Investment] Advisers Act and to formalize policies and procedures to address them.” Most state securities regulations have similar requirements for state registered investment advisers; however, every registered investment adviser must familiarize itself with the specific regulatory requirements of its governing regulatory authority.

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Developing and Implementing an Effective Customized Compliance Programs

September 19, 2013

RIA Compliance Consultants is hosting a webinar during which we will provide an overview of the requirement for an investment adviser to develop written supervisory policies and procedures in accordance with Rule 206(4)-7 under the Investment Advisers Act of 1940 (“Investment Advisers Act”). Under this rule U.S. Securities and Exchange Commission (“SEC”) registered investment advisers are required to adopt and implement written policies and procedures reasonably designed to prevent violations of the Investment Advisers Act and the rules that the SEC has adopted under the Act. Most state securities regulations have similar requirements. During this webinar, RIA Compliance Consultants will:

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SEC Issues Risk Alert Concerning Investment Adviser Business Continuity Plans

September 04, 2013

Rule 206(4)-7 under the Investment Advisers Act of 1940 (“Investment Advisers Act) requires registered investment advisers to have in place written supervisory policies and procedures. Although the rule does not specifically indicate the areas that must be addressed in an investment adviser’s written supervisory policies and procedures, the final rule release indicated some issues that should be addressed in all investment advisers’ written supervisory policies and procedures to the extent they are relevant to the investment adviser; one of these issues is business continuity plans.   As a fiduciary, an investment adviser has a responsibility to take the appropriate steps to protect the clients’ interests from risks resulting from the investment adviser’s inability to provide advisory services due to a disruption in business, like a natural disaster; therefore, all investment advisers should have a business continuity and disaster recovery plan.  The business continuity and disaster recovery plan should provide guidance regarding the steps and actions that should be taken in the event of an unanticipated interruption of normal business operations.  When developing a plan specific to the advisory firm, each investment adviser is encouraged to consider all of the firm’s advisory services and functions, consider any possible significant business disruptions that may occur, and determine a plan of action for each of these potential disruptions.

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