IM Guidance Update February 2017 Inadvertent Custody: Advisory Contract versus Custodial Contract Authority The U.S. Securities and Exchange Commission’s Division of Investment Management recently released guidance to alert investment advisers that they “may inadvertently have custody of client funds … Read More ›
In the No-action letter, the SEC clarifies that the Commission believes that a letter of instruction or other similar asset transfer authorization arrangement established by a client and submitted by an investment adviser to the qualified custodian would … Read More ›
The Five Most Frequent Compliance Topics Identified in OCIE Examinations of Investment Advisers Compliance Rule Rule 206(4)-7 makes it unlawful for an adviser to provide investment advice unless it (1) adopts and implements written policies and procedures reasonably designed … Read More ›
ADV season is upon us, and we’re hoping to make it easier on you! We’ve compiled an ADV Checklist with notes and commentary, and it is available for download in our Compliance Library. Let us know how else we … Read More ›