Investment Advisers

The SEC expects that advisers will produce truthful ads. Trouble can come if a firm puts out false or misleading marketing.   Investment Advisers Act rule 206(4)-1 ...
Investment Advisers Act rule 206(4)-7 requires that an SEC-registered investment adviser must review the adequacy and effectiveness of its policies and procedures at least annually.  ...
Remember, you don't have to achieve best execution but you should seek it. As a 2001 speech by former OCIE Director Lori Richards makes clear, ...
Advisers Act Rule 204-2 – the books and records rule – is the longest in the act at more than 4,000 words. It’s also among ...
The compliance program rule (Investment Advisers Act rule 206(4)-7) requires that all SEC-registered investment advisers adopt and implement written policies and procedures reasonably designed to ...
While many Advisers Act rules are principles-based – meaning it’s up to the registered entity to put policies in place to reasonably comply with the ...
The SEC’s Office of Compliance Inspections and Examinations is tasked with examining the nearly 12,000 SEC-registered investment advisers.  All the records of a registered adviser ...
Perhaps no Advisers Act rule challenges firms more than the custody rule.   It’s technically known as rule 206(4)-2. The intent is to protect client assets.   It was ...
Cybersecurity currently is a top priority for the SEC’s examination staff.  An initial “Phase 1” cybersecurity sweep of 49 investment advisers and 57 broker-dealers conducted ...
As a hand fits a glove, so do disclosure and fiduciary duty meld to form a bond in the adviser’s world. No document more dramatically ...
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