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 ›

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 ›

Proposed Compliance Rule Amendments

On May 20th, 2015 the SEC proposed “…rules, forms, and amendments to modernize and enhance the reporting and disclosure of information by investment advisers and investment companies.” In plain English, that means more information reported to the SEC and the … Read More ›

Additional Insight on Code of Ethics Questions

Q: Does Rule 204A-1 require reporting on company sponsored (or not sponsored, such as for a spouse) 401(k) plans if the asset type needs to be reported? To answer your question, first we will step back to the requirements. Rule … Read More ›