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Cash Solicitation (27)
Your search for Cash Solicitation returned 27 results.
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2/14/2019 | Content area: Investment Adviser
For the first time in two years, OCIE’s 2019 exam priorities letter didn’t call out robo-advisers as a key focus (IA Watch, Jan. 2, 2019). But does th...
11/09/2018 | Content area: Investment Adviser
How much would you pay to gain new clients? Some advisers are paying solicitors a handsome chunk of change.   “Solicitors will receive ongoing compens...
10/31/2018 | Content area: Investment Adviser
This Risk Alert includes observations by OCIE staff and is intended to assist investment advisers in identifying potential issues and adopting and imp...
10/31/2018 | Content area: Investment Adviser
It’s difficult to confuse the plain dictates of the cash solicitation rule, Advisers Act rule 206(4)-3, yet it seems some advisers have done just that...
10/24/2018 | Content area: Investment Adviser
A peer shares a Word file that is a checklist to use before hiring any solicitor, finder, third-party placement agent or such.
5/23/2018 | Content area: Investment Adviser
A peer shares the firm's statement that solicitors must sign.
2/15/2018 | Content area: Investment Adviser
Among the plethora of changes you face in updating your new Form ADV, Part 1 you’ll find two items that zero in on your payment for client referrals. ...
1/09/2017 | Content area: Investment Adviser | Broker-Dealer
John Rafal, Essex’s then President and CEO, and Peter Hershman, a Connecticut attorney, fraudulently schemed to circumvent the rule regarding payments...
1/09/2017 | Content area: Investment Adviser | Broker-Dealer
Rafal became concerned that his clients and others had heard rumors about him, including that Rafal was under investigation for engaging in a securiti...
6/30/2016 | Content area: Investment Adviser
In an ideal world, compliance and accounting would be linked when it comes to paying solicitors like July and fireworks are intertwined.   But perfect...
6/10/2016 | Content area: Investment Adviser
The compliance job can resemble a rerun of your favorite TV show. You’ve seen it before but you can’t turn away.   Take educating sales staff about th...
5/03/2016 | Content area: Investment Adviser
A peer shares the firm's compliance P&Ps for referrals and use of solicitors.
4/27/2016 | Content area: Investment Adviser
A peer shares the firm's contract it uses with solicitors.
4/27/2016 | Content area: Investment Adviser
A peer passes on an example of a contract in a solicitation arrangement.
4/27/2016 | Content area: Investment Adviser
Northpoint Compliance in Point Pleasant, N.J., shares its checklist for complying with Advisers Act rule 206(4)-3, the cash solicitation rule.
4/27/2016 | Content area: Investment Adviser
A peer gives IA Watch the firm's compliance policies and procedures around the use of solicitors.
9/30/2015 | Content area: Investment Adviser
We would not recommend enforcement action to the United States Securities and Exchange Commission ("Commission") under Section 206(4) of the Investmen...
5/20/2015 | Content area: Investment Adviser
This has become standard practice -- providing relief under Advisers Act rule 206-4(3) to permit a guilty party to continue to offer cash solicitation...
10/03/2014 | Content area: Investment Adviser | Broker-Dealer | CPO/CTA | Private Fund
(a) It shall be unlawful for any investment adviser required to be registered pursuant to section 203 of the Act to pay a cash fee, directly or indir...
3/24/2014 | Content area: Investment Adviser
The principles-based regulation of the Advisers Act doesn't contain many definite prohibitions but one bars cash payments to a third-party solicitor. ...


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