Tag Archives: Compliance Testing

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 →

Posted in Uncategorized | Tagged , , , | Leave a comment

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 →

Posted in Uncategorized | Tagged , , | Leave a comment

Disaster Recovery Plans

Posted on October 25, 2017 by

With all of the disasters in the past couple of months (hurricane, fires, floods) now is a great time to determine the adequacy of  your Disaster Recovery Plan (“Plan”).  You are required to “test” your  Plan each year.  Riding out … Continue reading →

Posted in Uncategorized | Tagged , , , , | Leave a comment

Cybersecurity Checklist

Posted on October 16, 2017 by

At the NASAA (North American Securities Administrators Association) annual meeting last month, the group was presented with a tool for state-registered advisers to help them assess their cybersecurity preparedness. The NASAA Cybersecurity Checklist for Investment Advisers includes 89 assessment areas … Continue reading →

Posted in Uncategorized | Tagged , , , | Leave a comment

DoL – should I continue to prepare?

Posted on November 16, 2016 by

There is a lot of talk about whether President-elect Trump will stop the DoL Fiduciary Rule.  As Michael Kitces mentioned in his column last week: “Because the reality is that while the rule will not be enforced until next April – after … Continue reading →

Posted in Uncategorized | Tagged , , , | Leave a comment

FinCEN Update: Advisory on Email Compromise Fraud Schemes

Posted on September 7, 2016 by

FinCEN Issues Advisory to Financial Institutions on E-Mail Compromise Fraud Schemes The Financial Crimes Enforcement Network (FinCEN) today issued an advisory to help financial institutions guard against a growing number of e-mail fraud schemes in which criminals misappropriate funds by … Continue reading →

Posted in Uncategorized | Tagged , , , , , , | Leave a comment

Cloud Provider Due Diligence

Posted on December 4, 2015 by

After the recent enforcement action against a financial advisor for failing to complete the proper due diligence on their cloud provider which ended in a compromise to their data, I am rerunning my blog earlier this year regarding Cloud Provider … Continue reading →

Posted in Uncategorized | Tagged , , , , | Leave a comment