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Cash Solicitation

Proposal would rename old rule, keep some elements and change others
Commission proposing tweaking record-keeping rule in light of advertising proposal
SEC proposes changing the advertising rule for the first time in decades
Cetera has paid cash fees to approximately 350 banks to, among other things, solicit investment advisory clients on behalf of Cetera. As part of this ...
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). ...
Best practices for complying with the cash solicitation rule
This Risk Alert includes observations by OCIE staff and is intended to assist investment advisers in identifying potential issues and adopting and implementing effective compliance ...
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. ...
A peer shares a Word file that is a checklist to use before hiring any solicitor, finder, third-party placement agent or such.
A peer shares the firm's statement that solicitors must sign.
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 ...
John Rafal, Essex’s then President and CEO, and Peter Hershman, a Connecticut attorney, fraudulently schemed to circumvent the rule regarding payments for client solicitations. Rafal ...
Rafal became concerned that his clients and others had heard rumors about him, including that Rafal was under investigation for engaging in a securities law ...
In an ideal world, compliance and accounting would be linked when it comes to paying solicitors like July and fireworks are intertwined.   But perfection ...
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 ...
A peer shares the firm's compliance P&Ps for referrals and use of solicitors.
A peer shares the firm's contract it uses with solicitors.
A peer passes on an example of a contract in a solicitation arrangement.
Northpoint Compliance in Point Pleasant, N.J., shares its checklist for complying with Advisers Act rule 206(4)-3, the cash solicitation rule.
A peer gives IA Watch the firm's compliance policies and procedures around the use of solicitors.
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