An investment adviser posts a seemingly innocuous comment to his firm’s social networking profile page, congratulating his colleagues on a successful year selecting investments. Another adviser, upon realizing that one of her long-time clients has recently moved and did not receive the firm’s new Form ADV brochure, quickly sends an e-mail to the client and attaches the requested documents.
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A New View of How Technology Will Change the Emerging Crytpo-Economy
From the top of the world, it’s amazing what you can see. I recently had the opportunity to travel to the United Arab Emirates to speak in Dubai at the 7th Edition of the Alternative Investment Management Summit. While I was there, I took a few moments to ride to the top of the Burj … Continued
SEC Retail Investor Focus Turns Towards Registered Investment Companies
Earlier this year when the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2018 examination priorities, OCIE stated that a core priority was to protect retail investors, including seniors and individuals saving for retirement. OCIE is now continuing this effort by focusing on mutual funds and exchanged-traded funds (together, the “Funds”) as the … Continued
SEC Alerts Investment Advisers to Review Solicitor Arrangements
On October 31, OCIE issued a new Risk Alert for investment advisers with solicitor arrangements. The SEC periodically releases risk alerts to notify the industry of deficiencies they are finding during examinations, and this latest alert puts investment advisers with solicitor arrangements on notice to check their solicitor agreements, policies and procedures, and disclosure documents. … Continued
Pennsylvania Sounds Warning Bell Over Client Credentials and Custody
The Pennsylvania Department of Banking and Securities (PDOBS) has indicated in recent guidance two concerns related to investment advisers using client credentials to access a custodial account(s). In the letter dated September 25, 2018, PDOBS indicates that the use of client credentials may create custody and is considered to be a dishonest and unethical practice. … Continued
San Diego 2018 Conference Gallery
Ascendant/CSS San Diego Conference Another compliance conference is in the books. We had a great time in San Diego, and we think our attendees did, too. We hope to see you in Miami! (Click on photos to view full size.)
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