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

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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

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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

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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

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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

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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

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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

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