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 →

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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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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 →

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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 →

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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 →

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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 →

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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 →

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Cybersecurity-getting staff interested

Posted on February 24, 2015 by

I was listening to a webinar the other day and one of the presenters said something that really got my attention.  A question was asked how do you get employees to care about cybersecurity.  The response: If a firm no longer … Continue reading →

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Valuations

Posted on August 5, 2014 by

The SEC has increased focus on valuation of non-traded assets.  If you have any non-traded assets in client portfolios that you bill on, be sure to have a policy on how you value these assets.  I suggest a conservative, written … Continue reading →

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Cybersecurity-6 critical questions you should know the answers to

Posted on July 14, 2014 by

Cybersecurity is a word much in the news of late.  The real question for me is – what is it really and what can and should the RIA firm be prepared to address regarding cybersecurity. With that in mind I … Continue reading →

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