SEC Proposals – ADV Part 3

May 11, 2018

On April 18, 2018, the Securities and Exchange Commission (SEC) voted to propose rules and interpretations that, among other things, are designed to enhance the transparency of investor’s relationships with investment advisers. Two of the SEC’s proposals that pertain to investment advisers are:

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SEC Risk Alert – Frequent Advisory Fee and Expense Compliance Issues

April 13, 2018

On April 12, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) of U.S. Securities and Exchange Commission (“SEC”) released a Risk Alert, “Overview of the Most Frequent Advisory Fee and Expense Compliance Issues Identified in Examinations of Investment Advisers.” The risk alert provides a list of compliance issues frequently identified in OCIE examination deficiency letters  relating to fees and expenses charged by SEC registered investment advisers.  Click here to read the SEC’s Risk Alert.

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Cherry Picking – SEC Cease-and-Desist Proceeding

March 28, 2018

In March 2018 the U.S. Securities and Exchange Commission (SEC) instituted an administrative cease-and-desist proceeding against an investment adviser firm in response to an alleged fraudulent “cherry-picking” scheme. The SEC asserts that from 2012-2015 the investment adviser firm disproportionately allocated profitable trades to a personal account, while disproportionately allocating unprofitable trades to client accounts. The firm, which had approximately $7.5-$9 million in assets under management, was fined $48,000 by its state securities regulator for failure to enforce its own supervisory procedures concerning trade allocation. Specifically, the state regulator found the investment adviser firm did not always pre-allocate block trades and did not retain a record of how block trades were pre-allocated. Click here to read the SEC’s full action.

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SEC Compliance Outreach Program – Date Set for National Seminar

February 14, 2018

The U.S. Securities and Exchange Commission (SEC) recently announced that its Compliance Outreach Program National Seminar for investment adviser firms will be held on Thursday, April 12, 2018 in Washington, DC.  This SEC event is designed to help chief compliance officer make improvements to his or her investment adviser firm’s compliance program.  For an employee of an SEC registered investment adviser firm to attend in person, he or she can register online at https://regandsurvey.sec.gov/NoviSurvey/TakeSurveyPage.aspx?s=be9d4ac36e2c40e19efaef0ce7079d06&tsid=8ff8c4079869425ea960fd3130c3cdff&c=en-US .  Additionally, the seminar will be broadcast live via the Internet which can be accessed at sec.gov .

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Protecting Senior Investors

February 06, 2018

On Jan. 24, 2018 the United States House of Representatives passed the Senior Safe Act.  The Senior Safe Act (referred to as “the Act,” formerly H.R. 3758) encourages financial services firms to train employees  to spot elder abuse, while granting limited immunity to individuals at financial institutions who report such abuse to law enforcement or regulators in accordance with the Act.

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