Update: SEC Rule Change Proposal!

The U.S. Securities and Exchange Commission (the “Commission”) recently published a series of proposed rule changes, including a change to the “accredited investor status” verification requirement under Rule 506(c) of Regulation D. My RIA Lawyer responded to the proposal on behalf of our private fund clients. Please read our full comment letter to the Commission […]

What violations are catching FINRA’s attention?

Quarantine doesn’t slow down suitability violations. FINRA is consistent in their review of unsuitable recommendations. Despite this being a hot topic for FINRA and all the cases they consistently have, there are violations happening at an alarming rate. Here are the main points to consider:   1: Review your WSPs for suitability and make sure […]

Are your disclosures (or lack of) going to get you in trouble?

The SEC started an initiative a couple years ago ordering firms to turn themselves in if they had failed to fully and fairly disclose their conflicts of interests in selecting for their advisory clients more expensive mutual fund share classes. The initiative allowed firms to self-report and return money to harmed investors.   This initiative […]

The SEC is Proposing a Modernization of the Framework for Fund Valuation Practices

This is huge news. We haven’t seen this addressed since 1970. The proposal reflects the vast changes that have taken place over the years. It also recognizes the important role that funds’ investment advisers may play and the expertise they may provide. This new rule is designed to explain how fund boards can satisfy their […]

Is your Cybersecurity Program Air Tight?

On January 27th 2020 the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued examination observations related to cybersecurity and operational resiliency practices taken by market participants.  OCIE observed a wide range of industry practices which included governance and risk management, access rights and controls, data loss prevention, mobile security, incident response […]

What You DIDN’T Know About Making Recommendations

Did you know that as of July 2019, the SEC has adopted Regulation Best Interest (Reg BI)? This new standard of conduct requires you to act in the best interest of the retail customer at the time the recommendation is made, without placing your financial or other interest ahead of the retail customer’s interests. So, […]

Cybersecurity: Are You Protected?

Understanding Cyber Insurance Guest Blog Post by Linda M. Vecoli CPCU RPLU and Emma Feloni   Are you concerned about the security of your data? Do you know how to better protect your business if an incident occurs? We invited the experts from Starkweather & Shepley Insurance Brokerage Inc. to shed some light on the […]

Do you know what happened this past week?

FINRA provides more guidance on communications with clients after brokers leave. FINRA moves forward on new rule proposals for broker-dealers and brokers with a disproportionately high number of disclosures. 2 former Woodbridge directors have been charged for role in massive Ponzi scheme. State of Texas fines Louisiana- based Integrity RIA $12,500 for providing investment advisory […]