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Compliance Best Practices
The DOL maintains its new rule is 'generally consistent' with the SEC’s fiduciary duty interpretation for advisers and Reg BI for B-Ds
As with exams over the past year, the DOE quizzed about the use of electronic communications for business purposes
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 ...
You may not always agree with your regulator’s stance but you often have little choice but to heed it
Compliance officers must remain vigilant, and their bosses need to provide “the proper resources” to compliance departments, counseled the SEC Division of Examinations Director Richard ...
“The central question is, ‘Are you breaching your fiduciary by focusing on these ‘political’ questions or are you actually upholding your fiduciary by upholding value ...
Gain ideas from this adviser's code of ethics
Heed the lessons of the SEC’s latest off-channel communications enforcement action against an adviser and you may well sidestep a similar fate
"As with the recordkeeping cases and, frankly, all our cases, we consider whether a firm self-reported and cooperated with our investigation"