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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
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
Posted in Uncategorized
Tagged Chief Compliance Officer, compliance, custody, IA regulations, Investment Advisor, SEC regulations
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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
Posted in Uncategorized
Tagged Chief Compliance Officer, IA regulations, Investment Advisor, SEC regulations
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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
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
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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