The FINRA 2024 Entitlement Certification period will begin on Monday, April 15. This is when FINRA begins requiring all Super Account Administrators (“SAA”) to certify the other administrators and users with accounts on the IARD/Web CRD system. The SAA for your investment adviser firm has the ability to create/delete other administrators and user accounts. An administrator can create/delete user accounts. For more information about the importance and responsibilities of the SAA, see the following website: https://www.finra.org/filing-reporting/entitlement/super-account-administrator-saa
Beware of Phishing Emails Impersonating FINRA
On Thursday, April 4, we received numerous inquiries from investment adviser firm owners and/or senior executives who had received an unexpected email supposedly from FINRA’s Chief Legal Officer or Chief Information Officer which utilized an email address ending in @ data-finra .org. In response, our Consulting Team contacted the IARD Entitlement Support Line which confirmed that these emails did not originate from FINRA.
Learn About the Exemption for Investment Advisers from New Beneficial Ownership Reporting Requirements
February 02, 2024
With the new requirements that corporations, limited liability companies and other entities report the identities of their beneficial owners to the Financial Crimes Enforcement Network (“FinCEN”), the chief compliance officer (“CCO”) of an investment adviser firm and sponsors of pooled investment vehicles should be aware that certain investment adviser firms and pooled investment vehicles are eligible for an exemption from FinCEN’s beneficial ownership reporting requirements.
Lawsuit Filed Against Montana for Discriminatory Investment Adviser Representative Registration Fees
January 13, 2024
Litigation Alert
According to the Daily Montanan, a class-action lawsuit has been filed against the State of Montana. This lawsuit challenges the constitutionality of a licensing fee structure imposed on non-resident investment adviser representatives and securities salespersons, alleging it violates the privileges and immunities clause of the United States Constitution.
SEC’s Investor Advocate Releases Reports on Mandatory Arbitration Clauses in Investment Advisory Agreements
December 08, 2023
The Office of the Investor Advocate of the U.S. Securities and Exchange Commission (“SEC”) recently released a report about the SEC staff’s study of mandatory arbitration clauses in investment advisory client agreements used by investment adviser firms registered with the SEC.
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