Tag Archives: due diligence

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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Wire transfers – things to consider

Some things to consider when you receive a request for a wire transfer or check  from a client: Confirm the request with the client via phone BEFORE you send them anything to sign. If a hacker is controlling their email, … Continue reading

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Firm Censured for Failing to Disclose Investment in Service Provider

from Cipperman Compliance  The SEC fined and censured a private equity fund manager for failing to disclose that the principals had personally invested in an IT firm that it had engaged. The respondent utilized the IT firm to perform due … 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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Advertising Another Firm’s Performance

“When an investment adviser echoes another firm’s performance claims in its own advertisements, it must verify the information first rather than merely accept it as fact.”     – Andrew J. Ceresney, Director, SEC Enforcement Division. Keep this in mind … Continue reading

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Due Diligence on Alternative Investments

At a recent NAPFA conference there was an interesting vendor in the exhibit hall –   Mick/Law P.C. is a specialty firm providing due diligence and a broad range of legal service to its valued clients focusing on representation of … Continue reading

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Is Sending a Fax Secure?

If you use a hardwired fax machine – those communications are deemed to be secure. However, if you use an electronic fax service, those faxes may or may not be secure. If the fax is sent via email to your … Continue reading

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10 tips for Protecting Data

From contractual arrangements pertaining to data breach expenses to encryption of data by cloud providers, and from written assurances to insurance, here are 10 tips to protecting and transferring risk. Inventory and Classify Your Data Know what data your firm … 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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IA Charged with Failing to Adopt Proper Cybersecurity Policies and Procedures

On September 22, 2015, the SEC announced that a St Louis-based investment adviser agreed to settle charges that it failed to establish the required cybersecurity policies and procedures in advance of a breach that compromised the personally identifiable information (PII) … Continue reading

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