Regulatory Reminder for State Registered Investment Advisers – Submission of Annual Financial Statements in Certain States

March 15, 2019

As your state registered investment adviser firm completes its Form ADV Annual Amendment, it’s important not to forget that many state securities regulators also require a state registered investment adviser firm to submit annual financial statements and/or other documents directly to the state securities regulator (outside of the IARD/CRD system).

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Cybersecurity Survey – Nebraska Registered Investment Advisers

January 22, 2019

On December 3, 2018 the Nebraska Department of Banking and Finance (NDBF) released their 2018 Cybersecurity Survey of Nebraska-Registered Investment Advisers. NDBF surveyed fifty-seven Nebraska registered investment advisers. The survey focused on devices used in advisory activities, Wi-Fi access points, passwords, encryption policies, and anti-virus/anti-malware services. The full report can be viewed here.

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2019 SEC Examination Priorities

December 27, 2018

On December 20, 2018, the Office of Compliance Inspections and Examination (“OCIE”) of the U.S. Securities Exchange Commission (“SEC”) released its 2019 Examinations Priorities for SEC registered investment advisers. After completing over 3,150 investment adviser examinations in 2018, a 10 percent increase over 2017, the SEC outlined several themes for the focus of investment adviser examinations which include the following:

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SEC Risk Alert – Electronic Messaging

December 19, 2018

December 17, 2018 the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) released a new National Exam Program Risk Alert Relating to Electronic Messaging. The purpose of the risk alert is to remind SEC registered investment advisers of their obligations when their supervised persons use electronic messaging and to help SEC registered investment advisers improve their systems, policies, and procedures by sharing the SEC staff’s observations from its investment adviser examinations.

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Deadline for Receipt of Preliminary Renewal Statement Payments Quickly Approaching

December 05, 2018

The deadline for investment advisers to submit their Preliminary Renewal Statement payment is quickly approaching. FINRA must be in receipt of the full payment listed on the Preliminary Renewal Statement by December 17, 2018. Investment advisers with sufficient funds in their Flex-Funding Account to cover the Preliminary Renewal Statement payment will have funds automatically transferred beginning on December 17, 2018 to the Renewal Account to cover total renewal fees owed. Automatic transfers will be conducted every day after December 17, 2018 until the WEB CRD/IARD shuts down for year-end processing on December 27, 2018. Investment advisers that choose to mail in their payments are advised to do so now to avoid delays and to ensure funds are received by the deadline. If your investment adviser would like assistance with the annual renewal service, click here for more information on or to purchase RIA Compliance Consultants’ IARD Renewal Program and ADV Amendment Service. If you have questions regarding these or any of the other services offered by RIA Compliance Consultants, contact your support person or Amanda Erwin (877) 345-4034 Ext. 115.

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