Category Archives: Uncategorized

SEC Exams and the DOL Rule

Posted on June 8, 2018 by

If your Policies and Procedures Manual says you do ‘X’ then you should be doing it.  In the past year I have added a policy for the DOL Rule to client Policies and Procedures Manuals.  Examiners have been asking about … Continue reading →

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DOL Fiduciary Rule – update

Posted on May 10, 2018 by

Although it appears that the federal court decision vacating the DOL Fiduciary Rule was supposed to take effect on May 7, 2018, the DOL releases a statement continuing its policy of non-enforcement given “uncertainty about fiduciary obligations.” Firms that have … Continue reading →

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News regarding DOL Fiduciary Rule

Posted on March 16, 2018 by

Yesterday, March 15, 2018, the U.S. Court of Appeals for the 5th Circuit voted 2-1 to vacate the DOL Fiduciary Rule.  HOWEVER,  the effect of the decision only applies to the following three states within the 5th Circuit’s jurisdiction – Louisiana, … Continue reading →

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Cybersecurity Training Options

Posted on February 20, 2018 by

Cybersecurity is once again on the SEC’s OCIE exam priorities list.  There are many things that a firm can do to counter the concerns of Cybersecurity.  One of the most difficult items to counter is an employee and their inadvertent … Continue reading →

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SEC Fines and Bars CCO for Ignoring Compliance Problems

Posted on December 29, 2017 by

from Cipperman Compliance Services The SEC fined and barred an adviser’s Chief Compliance Officer from acting in a compliance or supervisory capacity because of his failures to remedy compliance deficiencies. The adviser hired an outside compliance consultant which recommended 59 … Continue reading →

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Three Firms Fined for Marketing Hypothetical Third Party Performance

Posted on December 11, 2017 by

from Cipperman Compliance Services, LLC The SEC censured and fined three more investment advisers in connection with marketing F-Squared’s misleading hypothetical performance information. One of the firms agreed to pay $8.75 Million in disgorgement, fines, interest and another agreed to … Continue reading →

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Renewal Fees

Posted on December 6, 2017 by

Preliminary Renewal Statements are available on the IARD.  This statement includes the fees due to states for 2018.  These fees are due whether you are a state or an SEC advisor. Payment is due on or before December 18, 2017. … Continue reading →

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