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Advertising: Exam Focus (28)
Your search for Advertising: Exam Focus returned 28 results.
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3/29/2018 | Content area: Investment Adviser
It’s not a good sign when an adviser’s employee discovers he’s the firm’s CCO by reading its Form ADV.   But that’s how Richard Tomney found out he wa...
6/29/2017 | Content area: Investment Adviser
An attorney for Ray Lucia, the investment adviser who has spent the last four years challenging an SEC ALJ finding that he engaged in misleading adver...
11/19/2015 | Content area: Investment Adviser
The fallout from the F-Squared Investments case from late last year carries on. The then-largest marketer of index products using ETFs filed for Chapt...
5/19/2015 | Content area: Investment Adviser | Private Fund
Three strikes and you’re out. A critical SEC exam best practice is to make sure you address and correct deficiencies previously cited by the Commissio...
3/23/2015 | Content area: Investment Adviser | Private Fund
It goes back some time, SEC examiners’ interest in GIPS at those firms that claim compliance with those standards (IA Watch, Nov. 22, 2010). The SEC’s...
10/16/2014 | Content area: Investment Adviser | Private Fund
The SEC’s rules regarding advertising and marketing were developed long before the internet could have ever been imagined but that doesn’t mean your f...
9/25/2014 | Content area: Investment Adviser | Private Fund
Even the SEC recognizes its advertising and marketing rules for advisers aren’t easy.   “Advertising and marketing is a really challenging and difficu...
6/30/2014 | Content area: Investment Adviser
It's common for firms to show potential investors their performance gauged against an index, say the S&P 500. You can even come up with a "customized"...
6/02/2014 | Content area: Investment Adviser | Private Fund
It isn't often that the SEC pursues charges against advisers for GIPS violations and even more unusual for the agency to fine a former CCO hundreds of...
2/03/2014 | Content area: Investment Adviser | Private Fund
Three years ago, Mark Grimaldi, the CCO who runs Navigator Money Management ($115M in AUM) in Wappingers Falls, N.Y., co-founded the newsletter The Mo...
12/16/2013 | Content area: Investment Adviser | Private Fund
While it's a confirmed best practice for compliance to review all firm advertising, the act doesn't guarantee a firm or an individual will escape liab...
7/15/2013 | Content area: Investment Adviser
Ray Lucia built an empire based on his Buckets of Money(R) strategy. He traveled the country like a pied piper, holding seminars, luring in clients, t...
4/22/2013 | Content area: Investment Adviser
Max Zavanelli has had his troubles when it comes to advertising the performance of his firm, ZPR Investment Management ($164M in AUM) in Orange City, ...
12/12/2012 | Content area: Investment Adviser | Private Fund
Click here to open a Word file that a peer shares. It is a template for how to document testing around advertising.
1/24/2011 | Content area: Investment Adviser
The SEC expects your policies and procedures to include a look at the "accuracy of disclosures made" in advertisements but it doesn't lay out a concre...
3/08/2010 | Content area: Investment Adviser
Satisfying SEC examiners when it comes to best execution could be as simple as having a process that seeks best execution and routinely following it b...
1/01/2007 | Content area: Investment Adviser
1/01/2007 | Content area: Investment Adviser
1/01/2007 | Content area: Investment Adviser
1/01/2007 | Content area: Investment Adviser


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