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 […]

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 […]

Annual Compliance Reviews

Can you believe it?  It’s the last quarter of the year.  That means it’s time to look back and conduct an annual compliance review. What is an annual compliance review? Each investment adviser registered with the SEC is required to adopt and implement written policies and procedures reasonably designed to prevent violations of the Investment […]