Firms must e-mail the DOL by Sept. 15th at QPAM@dol.gov, including “the legal name of the entity and any name the QPAM may be operating ...
The Division encourages advisers to reflect upon their own practices, policies, and procedures and to implement any appropriate modifications to their training, supervisory, oversight, and ...
IA penalized $60K for running afoul of the Commission's pay-to-play rule
A staffer at the adviser "made a campaign contribution to a candidate for elected office in Minnesota, which office had influence over selecting investment advisers ...
"Individual liability for disclosure failures related to AI as a security threat may therefore be of particular interest to you"
"This case is yet another illustration of the overbreadth of the pay-to-play rule and another reminder of the way the rule hampers legitimate political participation"
"The regulatory gap described, therefore, is more optical than substantive; closing it amounts to little more than grade-grubbing"
The resounding message is don't advertise hypothetical performance on your public websites
Bradesco disseminated hypothetical performance in advertisements to a mass audience rather than presenting hypothetical performance relevant to the likely financial situation and investment objectives of ...
Credicorp failed to adopt and implement policies and procedures reasonably designed to ensure that the performance was relevant to the likely financial situation and investment ...