Monthly Archives: February 2017

Standing LOAs as Custody – additional information

The No-Action Letter discussed in yesterday’s blog contains seven conditions that, if met, would allow an adviser to escape the need for a surprise exam: 1. The client provides an instruction to the qualified custodian, in writing, that includes the … Continue reading

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Standing LOAs Cause Advisers to Have Custody

from Cipperman Compliance Services LLC The staff of the SEC’s Division of Investment Management, in a recent No-Action Letter, has opined that an adviser has regulatory custody of client assets where a client grants even limited authority to transfer assets … Continue reading

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Consistency between Code of Ethics and Actual Gifts Received

from Cipperman Compliance Services The SEC censured and fined an investment consultant and its principal $700,000 for lying about gifts received from recommended investment managers and performance information. The respondent’s marketing material claimed that neither the firm nor its principals … Continue reading

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Disaster Recovery testing opportunity

Today may be an opportunity to test your Disaster Recovery Plan – especially if you live in the North East.  With the NorEaster, you, or some of your employees, may not be able to get to the office.  Or you … Continue reading

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DOL Fiduciary NOT Yet Delayed by President Trump

from Michael Kitces Given the party-lines debate that has revolved around the Department of Labor’s fiduciary rule for the past year – ever since President Trump put the full force and backing of the White House behind the final rule … Continue reading

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5 ways to detect a malicious “phishing” email

from Carbonite For as long as there’s been email, there’s been email scams. At least since the time email first started gaining widespread popularity in the 1990s, phishing scams have been showing up in email accounts. They’re called ‘phishing’ emails … Continue reading

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