Simons Says: Changing of the Guards

Timothy M. Simons, CFA, CFP, CIPM, CSCP Senior Managing Member Focus 1 Associates LLC December 28, 2016     Fiduciary Rules As the end of 2016 nears, I would like to spend a little time talking about the SEC’s Fiduciary … Read More ›

SEC Exams are Escalating

  Although only small percentages (around 10%) of firms are actually examined each year, the SEC has found ways to cover more ground with the resources they have.  From a recent industry report, “SEC exams are on the rise with … Read More ›

Simons Says: Changing Custody Guidance?

Timothy M. Simons, CFA, CFP, CIPM, CSCP Senior Managing Member Focus 1 Associates LLC September 26, 2016   I want to briefly discuss a topic about which questions have arisen in the last couple of months that we thought had been … Read More ›

Top 6 SEC Compliance Deficiencies

Did you know?   1. Compliance Rule 2. Disclosure 3. Fiduciary Duty 4. Code of Ethics 5. Advertising Rule 6. Custody Rule   This fact was presented by the SEC’s Office of Compliance Inspections and Examinations’ (OCIE’s) assistant director, Renee … Read More ›

Changes to Form ADV and Rule 204-2 (Books and Records)

Form ADV On August 25, 2016, the Securities and Exchange Commission announced the adoption of amendments to the Investment Advisers Act of 1940 and Form ADV. Additional information on Form ADV will be required regarding separately managed accounts business, including … Read More ›

Pay to Play Rules in 2016 Election

    Linda F. Beckmann Managing Member August 22, 2016 As Mike Pence is currently Governor of Indiana and has authority over the Indiana Public Retirement System and the Indiana Education Savings Authority, contributions to the Trump campaign may violate … Read More ›

Adjustments to “Qualified Client” Dollar Thresholds

The SEC issued an order on June 14, 2016 approving inflation-related adjustments to the dollar amount tests in Rule 205-3 of the Investment Advisers Act of 1940. Under Rule 205-3, SEC-registered investment advisers are permitted to charge performance-based compensation to … Read More ›