Tag Archives: Compliance Testing

Disaster Recovery Plans

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

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?

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

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

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

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

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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