Monthly Archives: August 2016

Advertising Another Firm’s Performance

“When an investment adviser echoes another firm’s performance claims in its own advertisements, it must verify the information first rather than merely accept it as fact.”     – Andrew J. Ceresney, Director, SEC Enforcement Division. Keep this in mind … Continue reading

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Mobile Device Policy

If you allow your employees to use their own mobile devices to access your firm’s electronic data – you need a Mobile Device Policy.  Included in a Mobile Device Policy should be laptops, hard drives, smart phones, tablets, handheld computers, … Continue reading

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Policies and Procedures/Annual Review

Fortius Financial Advisors and Bollinger settle case of poor compliance P&P that didn’t prevent theft of client funds.  SEC proceedings in the matter of Fortius Financial Advisors, LLC, Jeff M. Bollinger, and Gary E. Oliver Bollinger was responsible for adopting … Continue reading

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Review of Marketing/Advertising for RIAs

When reviewing a marketing piece, what are the things that you should consider?   A few examples of a marketing piece include (but are not limited to): websites (including the blogs posted on the website) newsletters (including email newsletters) business … Continue reading

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Annual Compliance Review

If you haven’t completed or scheduled your annual compliance review, as required by Rule 206(4)-7, for 2015, time to do so.  Before you know it December will be here and you may not get a chance to do a thorough … Continue reading

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