Investment Advisers

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Peirce suggested being wary of simply counting cases and tallying penalties
Settlement follows criminal case plea that could land the CCO in jail
“Trust,” longtime DC pundit David Gergen once said, “is the coin of the realm in politics.” As long as SEC Chairman Jay Clayton has his ...
A sample code of ethics
This P&P comes courtesy of Michelle Jacko, CEO of Core Compliance and Jacko Law Group in San Diego.
Rulemaking recommendation on new disclosure framework for variable products coming
Eyes are peering upon a draft that could eventually become the SEC’s proposed new IA advertising rule. In yet another sign that a long-awaited proposal ...
SEC proposes derivatives rule, disclosure failures, CFTC aims for harmony
“Romeril faces the threat of reopened and renewed prosecution if he speaks up”
Michael Diamond once worked for Ringling Brothers but couldn’t have envisioned the circus he found himself part of when he applied to work at Worldwide ...
An adviser received this OCIE request letter in 2018. The exam focuses on ESG (environmental, social and governance) and SRI (socially responsible investing).
Richard Chen of Richard L. Chen PLLC in New York shares this checklist to help advisers when bringing on new clients.
“It’s better to take a conservative position” and disclose that you’ll make more money in a rollover
This is a copy of an adviser's OCIE document request letter from a 2018 exam that focused on custody.
The Enforcement Manual (“Manual”) is a reference for staff in the Division of Enforcement (“Division” or “Enforcement”) of the U.S. Securities and Exchange Commission (“SEC” ...
Ben Anderson, principal with Anderson PLC in Minneapolis, provides this checklist for advisers entering into contracts with vendors.
It’s a tight labor market for compliance officers but an open mind—and a few, key focused questions—might just help you build your A-Team.   “One ...
Marian Young didn’t believe she needed an attorney to ensure she complied with Advisers Act rules when launching her internet advisory firm. She read the ...
An adviser received this initial document request letter in 2019.
A peer shares the advisory firm's soft dollars checklist.

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