Tag Archives: rules

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

Posted in Uncategorized | Tagged , , , , , | Leave a comment

Allowing use of home wi-fi to access business data

If you allow employees to access business data via their home wi-fi, you will want to have some specific requirements in place.  Create a checklist to mitigate the risk of accessing business data from a home wi-fi.  Consider the following: … Continue reading

Posted in Uncategorized | Tagged , , , , | Leave a comment

Delivery of ADV Part 2

On an annual basis, a registered investment adviser must (i) deliver within 120 days of the firm’s fiscal year end, to each Client a free updated Form ADV, Part 2A that either includes a summary of material changes or is accompanied … Continue reading

Posted in Uncategorized | Tagged , , , | Leave a comment

Cybersecurity-getting staff interested

I was listening to a webinar the other day and one of the presenters said something that really got my attention.  A question was asked how do you get employees to care about cybersecurity.  The response: If a firm no longer … Continue reading

Posted in Uncategorized | Tagged , , , , , | Leave a comment

Electronic Communications Requirement for CA Registered Advisers

For those registered with the state of California, be advised of a new requirement.  The DBO (Department of Business Oversight) sent out a letter to all RIAs.  The new requirement is that each RIA must set up a designated email … Continue reading

Posted in Uncategorized | Tagged , , | Leave a comment

Mobile Device Policy

Almost everyone has at least one mobile device being used in their firm.  The question is – do you have a Mobile Device Policy?  If not, here are a few suggestions for what you might want to include: 1. Can … Continue reading

Posted in Uncategorized | Tagged , , , , | Leave a comment

Compliance Testing – Protecting Client Assets

Some testing to assist you in protecting your client assets: 1. Are clients actually receiving their custodial statements.  Ask clients during meetings to bring their statements. 2. When receiving an account transfer, wiring instructions or a check request from a … Continue reading

Posted in Uncategorized | Tagged , , , , , | Leave a comment

Use of “Unbiased”

Something I have been coming across frequently of late, the thought that as a fee-only RIA, the firm is unbiased and has no conflicts of interest.  Let me be the one to dispel that thought – you do have biases … Continue reading

Posted in Uncategorized | Tagged , , , , | Leave a comment

ADV Part 1 Changes

Included in the final rule regarding the amendments due to Dodd-Frank are many changes to ADV Part 1.  These changes to ADV Part 1 will apply to you whether you are a small, mid, or large sized advisor.  Tee new … Continue reading

Posted in Uncategorized | Tagged , , , , | Leave a comment

SEC Open Meeting: Dodd-Frank Act Amendments to the Investment Advisers Act

Mary Schapiro speaking about the switch rule for mid-sized SEC registered advisors. She isn’t the most exciting speaker, but the information is helpful if you are one of the advisers that is affected by this amendment. SEC Open Meeting: Dodd-Frank … Continue reading

Posted in Uncategorized | Tagged , , , | Leave a comment