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Cash Solicitation
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 gives IA Watch the firm's compliance policies and procedures around the use of solicitors.
Northpoint Compliance in Point Pleasant, N.J., shares its checklist
A peer passes on an example of a contract in a solicitation arrangement.
We would not recommend enforcement action to the United States Securities and Exchange Commission ("Commission") under Section 206(4) of the Investment Advisers Act of 1940 ...
This has become standard practice -- providing relief under Advisers Act rule 206-4(3) to permit a guilty party to continue to offer cash solicitation.
(a) It shall be unlawful for any investment adviser required to be registered pursuant to section 203 of the Act to pay a cash fee, ...
The principles-based regulation of the Advisers Act doesn't contain many definite prohibitions but one bars cash payments to a third-party solicitor. But even rule 206(4)-3 ...
The world of social media may be swaying the SEC's Division of Investment Management to update rules for advisers. The effort, announced at the recent ...
That new SEC and Department of Justice130-page compendium on the Foreign Corrupt Practices Act may leave you wanting when it comes to compliance guidance. But ...