Tag Archives: SEC regulations

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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Custody Rule Concerns

There has been a lot of discussion the last month or so about whether an advisor has custody, and therefore required to have an annual surprise custody audit. The SEC has in several exams stated that a custodian’s contract could … Continue reading

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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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