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Tag Archives: Compliance Testing
DOL Fiduciary Rule – update
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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Tagged compliance, Compliance Testing, DOL Fiduciary Rule, Investment Advisor
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Cybersecurity Training Options
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
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
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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Tagged compliance, Compliance Testing, cybersecurity, Investment Advisor
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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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Tagged Compliance Testing, DOL Fiduciary Rule, IA regulations, Investment Advisor
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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
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
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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Tagged compliance, Compliance Testing, cybersecurity, IA regulations, Investment Advisor, rules
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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
Cybersecurity-6 critical questions you should know the answers to
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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Tagged compliance, Compliance Testing, cybersecurity, Investment Advisor
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