Tag Archives: IA regulations

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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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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Disaster Preparation

In an article published on FinancialPlanning October 7, 2016, Carolyn McClanahan discussed the action plan her firm had in place as Hurricane Matthew was bearing down on her city. Here are some ideas that you may want to consider.  The … Continue reading

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Who Should NOT be the Chief Compliance Officer

RIA Failed to Conduct Annual Compliance Reviews and Appointed Admin as CCO from Cipperman Compliance Services The SEC fined and censured a registered investment adviser for failing to conduct annual compliance reviews and appointing a chief compliance officer without relevant … Continue reading

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DOL Fiduciary Rule – Begin Preparation Now

It may seem like the effective date of the DOL Fiduciary Rule is far off – April 2017; however there is much preparation to begin now.  My clients will be receiving a survey from me this week that will help … 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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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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Mobile Device Policy

If you allow your employees to use their own mobile devices to access your firm’s electronic data – you need a Mobile Device Policy.  Included in a Mobile Device Policy should be laptops, hard drives, smart phones, tablets, handheld computers, … Continue reading

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Policies and Procedures/Annual Review

Fortius Financial Advisors and Bollinger settle case of poor compliance P&P that didn’t prevent theft of client funds.  SEC proceedings in the matter of Fortius Financial Advisors, LLC, Jeff M. Bollinger, and Gary E. Oliver Bollinger was responsible for adopting … Continue reading

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Review of Marketing/Advertising for RIAs

When reviewing a marketing piece, what are the things that you should consider?   A few examples of a marketing piece include (but are not limited to): websites (including the blogs posted on the website) newsletters (including email newsletters) business … Continue reading

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