Tag Archives: compliance

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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The Fiduciary Rule, Distributions and Rollovers

information provided by Fred Reisch blog at FredReisch.com Now that it seems likely that the fiduciary rule and the transition exemptions will continue “as is” until at least July 1, 2019, it’s time to re-visit the fiduciary rule and the … Continue reading

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Be Aware When Wiring Funds for a Client’s Escrow

It has come to my attention that wiring funds to close an escrow for a client could end up with funds going to a hacker. My understanding is that most escrow companies will give the wiring instructions to the client … Continue reading

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SEC Explores Ways to Strengthen Compliance of Independent Advisers

SEC Explores Ways To Strengthen Compliance Of Independent Advisers (Mark Schoeff, Investment News) – At a recent compliance conference, the acting director of the SEC’s Office of Compliance Inspections and Examinations (OCIE) noted that the SEC has increasing concern about … Continue reading

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Standing LOAs as Custody – additional information

The No-Action Letter discussed in yesterday’s blog contains seven conditions that, if met, would allow an adviser to escape the need for a surprise exam: 1. The client provides an instruction to the qualified custodian, in writing, that includes the … Continue reading

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Standing LOAs Cause Advisers to Have Custody

from Cipperman Compliance Services LLC The staff of the SEC’s Division of Investment Management, in a recent No-Action Letter, has opined that an adviser has regulatory custody of client assets where a client grants even limited authority to transfer assets … Continue reading

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Disaster Recovery testing opportunity

Today may be an opportunity to test your Disaster Recovery Plan – especially if you live in the North East.  With the NorEaster, you, or some of your employees, may not be able to get to the office.  Or you … Continue reading

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