Tag Archives: Investment Advisor

DOL Prohibited Transaction Rule aka DOL Fiduciary Rule 3.0

Posted on August 23, 2021 by cindihill

The Department of Labor (DOL) Fiduciary Rule became effective February 16, 2021, with a compliance date of December 20, 2021. Under 3.0, advice to rollover or transfer an account is fiduciary advice…even though the prospect is not yet a client. … Continue reading →

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Update on PPP disclosure

Posted on May 7, 2020 by cindihill

FA Advisor magazine UPDATE TO THIS ARTICLE – THE DEADLINE TO RETURN HAS BEEN EXTENDED TO 5/14/20 Also, if you need to disclose the PPP loan on your ADV Part 2, it must be done within 30 days.  I believe … Continue reading →

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SEC Exams and the DOL Rule

Posted on June 8, 2018 by cindihill

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

Posted on May 10, 2018 by cindihill

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

Posted on March 16, 2018 by cindihill

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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SEC Fines and Bars CCO for Ignoring Compliance Problems

Posted on December 29, 2017 by cindihill

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

Posted on December 11, 2017 by cindihill

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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Renewal Fees

Posted on December 6, 2017 by cindihill

Preliminary Renewal Statements are available on the IARD.  This statement includes the fees due to states for 2018.  These fees are due whether you are a state or an SEC advisor. Payment is due on or before December 18, 2017. … Continue reading →

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ADV Part 1 Changes

Posted on November 17, 2017 by cindihill

As many of you are aware, the U.S. Securities and Exchange Commission (“SEC”) issued a final rule in August 2016, which significantly expands the information required in Form ADV Part 1. The compliance date for the rule is October 1, … Continue reading →

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Disaster Recovery Plans

Posted on October 25, 2017 by cindihill

With all of the disasters in the past couple of months (hurricane, fires, floods) now is a great time to determine the adequacy of  your Disaster Recovery Plan (“Plan”).  You are required to “test” your  Plan each year.  Riding out … Continue reading →

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