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The Securities Bureau of the Nebraska Department of Banking and Finance has proposed a new rule which would require investment advisers to develop and maintain physical and cybersecurity policies and procedures designed to protect client records and information.
On July 23, 2019 the Office of Compliance Inspections and Examination’s (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) released a Risk Alert about its assessment of the oversight practices of SEC-registered investment advisers who employ or employed individuals with disciplinary histories. Of the over 50 advisers that were examined, nearly all of the examined advisers received deficiency letters. The OCIE exams did not focus solely on supervisory practices as they relate to the individuals with prior disciplinary histories. Instead, OCIE reviewed the advisers’ supervisory practices firm-wide. OCIE’s findings relate to all investment advisers regardless of whether they have someone with a disciplinary history. The deficiencies identified related to compliance and disclosure issues, including undisclosed conflicts of interest.
On June 5, 2019 the U.S. Securities and Exchange Commission (SEC) voted on and approved package of rulemakings and interpretations, that includes the new Form CRS Relationship Summary, also known as the ADV Part 3. The ADV Part 3 is designed to be a short and accessible disclosure for retail investors that helps them compare information about firms’ investment advisory offerings. To help investment advisers understand what will be required by the Form CRS Relationship Summary/ADV Part 3, RIA Compliance Consultants created a new webpage, Form ADV Part 3 FAQs. The page features 25 questions with detailed answers about what will be required by investment advisers on the Form CRS Relationship Summary/ADV Part 3.
On June 5, 2019 the U.S. Securities and Exchange Commission (SEC) voted on and approved a CRS Relationship Summary also known as the ADV Part 3. The ADV Part 3 is designed to be a short and accessible disclosure for retail investors that helps them compare information about firms’ investment advisory offerings. The relationship summary is intended to inform retail investors about:
On June 5, 2019 the U.S. Securities and Exchange Commission (SEC) voted on and approved four rules relating to the proposed standards of conduct rulemaking package that was originally proposed in April 2018. The approved rulemaking package includes:
On May 21, 2019, the North American Securities Administrators Association (NASAA) released a model cybersecurity rule package. NASAA’s proposed rule would require investment advisers to adopt policies and procedures regarding information security and to deliver annually its privacy policy to clients.
On April 16, 2019, the United States Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a risk alert about “Compliance Issues Related to Regulation S-P – Privacy Notices and Safeguard Policies” to encourage investment adviser firms to review their written policies and procedures to, “ensure compliance with the relevant regulatory requirements.”
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).