Tag Archives: SEC regulations

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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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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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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Annual Compliance Review

If you haven’t completed or scheduled your annual compliance review, as required by Rule 206(4)-7, for 2015, time to do so.  Before you know it December will be here and you may not get a chance to do a thorough … Continue reading

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10 tips for Protecting Data

From contractual arrangements pertaining to data breach expenses to encryption of data by cloud providers, and from written assurances to insurance, here are 10 tips to protecting and transferring risk. Inventory and Classify Your Data Know what data your firm … Continue reading

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Advice regarding retirement accounts

As part of its examination sweep, the SEC is sending financial advisers a 13-page information request that includes 75 items.   The document focuses on the recommendations advisers make to rollover funds from a 401(k) account(s) to an individual retirement … Continue reading

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Minimize liability in the event of a Breach

A few items to consider that could minimize your liability in the event of a breach: Maintain only those records that must be maintained.  For terminated clients, remove all data, especially those records containing non-public client information from storage (cloud … Continue reading

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Disaster Recovery Testing Opportunity today?

For those of you with the winter weather approaching, keep in mind that now might be an opportunity to test your Disaster Recovery Plan.  If you are not able to get to the office, take a look at your plan. … Continue reading

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Annual Updating Amendment deadline change

The deadline for filing your Annual Updating Amendment is 90 days from the end of your fiscal year.  If your fiscal year ends December 31, then your deadline in 2016 is March 30th…not March 31st, because of the leap year. … Continue reading

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