Tag Archives: compliance

New Hacking Incident – be VERY Aware

A client recently sent me an email asking about a blank form he received in the mail. It was a MA-W Notice of Withdrawal form (it is a form for withdrawing registration as a municipal advisor).  It was sent without … Continue reading

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SEC Exams and the DOL Rule

If your Policies and Procedures Manual says you do ‘X’ then you should be doing it.  In the past year I have added a policy for the DOL Rule to client Policies and Procedures Manuals.  Examiners have been asking about … Continue reading

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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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News regarding DOL Fiduciary Rule

Yesterday, March 15, 2018, the U.S. Court of Appeals for the 5th Circuit voted 2-1 to vacate the DOL Fiduciary Rule.  HOWEVER,  the effect of the decision only applies to the following three states within the 5th Circuit’s jurisdiction – Louisiana, … 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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SEC Fines and Bars CCO for Ignoring Compliance Problems

from Cipperman Compliance Services The SEC fined and barred an adviser’s Chief Compliance Officer from acting in a compliance or supervisory capacity because of his failures to remedy compliance deficiencies. The adviser hired an outside compliance consultant which recommended 59 … Continue reading

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Three Firms Fined for Marketing Hypothetical Third Party Performance

from Cipperman Compliance Services, LLC The SEC censured and fined three more investment advisers in connection with marketing F-Squared’s misleading hypothetical performance information. One of the firms agreed to pay $8.75 Million in disgorgement, fines, interest and another agreed to … Continue reading

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