The SEC has taken enforcement actions against employers for language in their employment agreements that did not provide whistleblower protections. GQG Partners, a Florida based investment adviser was fined $500,000.
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IA Advertising: SEC’s DOE wants advisers to see the forest AND the trees – review those ads at least twice and from more than one angle. Recent exams results warn advisers not to use advertisements that are (i) materially misleading, (ii) not fair and balanced and/or (iii) including facts that can’t be substantiated.
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Most small companies (and the individuals that own and control them) will need to report under the Corporate Transparency Act (CTA), effective January 1, 2024, but the reports aren't due until January 1, 2025. See Lauri London's summary (and handy chart) of CTA requirements and definitions that you need to know.
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A Recent SEC Risk Alert describes financial firms’ complacency regarding identity theft prevention programs under the Red Flag Rule. Attention Registered Investment Advisers and Broker-Dealers.
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For RIAs that haven’t yet updated their Advertising and Marketing P&Ps, time is quickly running out. The compliance deadline for the new marketing rule is just weeks away and the SEC has set its sights on enforcement.
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Following a recent review of 130 Investment Advisers, the SEC’s Division of Examinations cited numerous deficiencies and warned of “financial harm to clients”. Our article identifies the most common flaws noted in the DOE’s latest Risk Alert.
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Avoiding Notable Compliance Issues that were identified by the SEC.
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The first Form CRS (Client Relationship Summaries) have been delivered and filed by investment advisors. But regulators are suggesting that firms could do a lot better.
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Investment Advisers: The SEC’s proposes lifting the reporting threshhold for 13F reporting from: $100 million to a $3.5 billion reporting threshold. This will reduce administrative burdens on thousands of investment advisers.
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Lauri London quoted in the April 13, 2020, Regulatory Compliance Watch newsletter.
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Lauri London shares an update on the Form CRS Risk Alert issued by the SEC’s Office of Compliance Inspections and Examinations.
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While the SEC thinks that it clarified Reg BI with its recently published, 42-page interpretation, we think that it raised questions for investment advisers that could force them to upgrade their policies, procedures, and compliance programs.
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The SEC's proposed new advertising rule presents significant changes for RIAs' Policies, Procedures, Books & Records requirements and testing.
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The SEC thinks that it “clarified” Reg BI when it published a new 42-page interpretation. But to us, it looks like investment advisers may need to make a wholesale upgrade of compliance programs. Read more…
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New Guidance from OICE encourages changes to Investment Advisers’ compliance programs to address specific risk. Off-the-Shelf compliance programs don’t cut it anymore.
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