Carl Ayers
Two new releases from the SEC’s Division of Investment Management add clarity to two issues that may affect you. 1. Foreign affiliates that fall ...
Despite several revisions of the SEC’s interpretation of the custody rule, the agency hasn’t budged on one tenet: having the ability to access a customer’s ...
A huge sigh of relief can be heard from the industry now that the Labor Department has announced it won’t enforce violations of its fiduciary ...
The unionized OCIE examiner worked a four-day, 10-hour per day schedule that allowed him to take off Fridays. But the firm he was examining kept ...
You’ve heard before the best practice of showing examiners a PowerPoint presentation about your firm on the first day of their visit (IA Watch, Sept. ...
The adviser followed the rules and disclosed a conflict and compensation on Form ADV that it received from a clearing broker. However, the adviser failed ...
Include in your definition of personally identifiable information any “security code, access code or password that would permit access to an individual’s financial account.” ...
This week, the CFA Institute’s executive body will weigh a proposal to change the GIPS’ rules to accept a mutual fund’s existing regulatory disclosures as ...
Sending routine account notices should be, well, routine. But programming errors and supervisory glitches can trump the best of intentions. And it will cost you. ...