Tag Archives: compliance

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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SEC Reviewing Multi-Branch Adviser Compliance

SEC Reviewing Multi-Branch Adviser Compliance from Cipperman Compliance Services The staff of the SEC’s Office of Compliance Inspections and Examinations issued a Risk Alert announcing its “Multi-Branch Adviser Initiative.” The Alert expresses concern about the “unique risks and challenges” for … Continue reading

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Custody Rule Concerns

There has been a lot of discussion the last month or so about whether an advisor has custody, and therefore required to have an annual surprise custody audit. The SEC has in several exams stated that a custodian’s contract could … Continue reading

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