Although many investment adviser firms desire to outsource the chief compliance officer role to an unaffiliated third-party independent contractor (“Outsourced CCO”), such an arrangement will be scrutinized and could be challenged by the securities regulator as a violation Rule 206(4)-7 or equivalent rule of the state securities regulator depending upon the facts and circumstances.
October 29, 2021
Investment adviser firms and investment adviser representatives must maintain active registrations and/or notice filing statuses with applicable jurisdictions/states. Unless properly renewed, all investment adviser firm and investment adviser representative licensing approvals expire December 31 each calendar year. To ensure that investment adviser firms and their investment adviser representatives are properly licensed in all necessary jurisdictions for 2022, renewal fees must be paid through the Investment Adviser Registration Depository (“IARD”) system.
July 14, 2021
The Investor Protection Bureau of the State of New York’s Office of Attorney General recently issued new guidance clarifying the state’s new process for registering investment adviser representatives (“IARs”). This guidance will be of particular interest to new and existing investment adviser representatives seeking registration in New York. Existing investment adviser representatives have until December 2, 2021 to comply with the registration requirement but must submit a Form U4 requesting investment adviser representative registration in New York on or before August 31, 2021.
June 09, 2021
Recently, several of our RIA clients have received suspicious emails claiming to be from FINRA. The suspicious emails used the subject line “New FINRA Request – (Firm Name),” and came from an email address with the domain, “@gateway-finra.org” Below is a screenshot of one of these suspicious emails.
RIA Compliance Consultants recently updated its sample form, Suitability – Retirement Plan Rollover – Client Acknowledgement.
RIA Compliance Consultants recently created a new Sample Form, Client as Investor/Owner in RIA – Checklist of Compliance Issues.
Nebraska Enacts Law Giving Investment Advisers Ability to Protect Seniors and Vulnerable Adults from Financial Exploitation
April 10, 2021
On Thursday, October 22, 2020 at 12:00 PM CDT, RIA Compliance Consultants, Inc. will host a compliance training webinar entitled, “Best Practices to Reduce the Risk of Arbitration and Litigation.” RCC is excited to have representatives from Unitifi and Lockton Affinity serve as panelists on this webinar. Patrick Griffin, an attorney from Kutak Rock, will also serve as a panelist during this discussion.