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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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

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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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