Tag Archives: Investment Advisor

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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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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Consistency between Code of Ethics and Actual Gifts Received

from Cipperman Compliance Services The SEC censured and fined an investment consultant and its principal $700,000 for lying about gifts received from recommended investment managers and performance information. The respondent’s marketing material claimed that neither the firm nor its principals … 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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Five steps to take when you suspect you are a victim of a cyber attack

from IAWatch Step 1: Contact your IT leader. Step 2: Assess if your system has been penetrated. Step 3: Detect the extent of the hack. Step 4: Notify clients – be aware of your state’s laws regarding alerting a client … 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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Preparing for Preliminary Renewal Reports

Time to prepare for the 2017 Renewals.  The Preliminary Renewal Statement will be ready for viewing on Monday, November 14th.   You may want to confirm that the states in which you are registered or noticed filed (if you are … Continue reading

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