Since we work in the investment advice and securities industry, it is axiomatic that we operate in a regulated environment. Employees in this field, from CEOs on down, and since time out of mind, have...

Almost a year ago the Department of Labor (DOL) adopted Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”). PTE 2020-20 allows investment advisors and broker-dealers to receive commissions, 12b-...

The amount of time spent on investment advisor compliance will vary widely between firms. Compliance for a registered investment advisor (RIA) firm will depend on the following: o Is the investment ad...

In a famous passage of William Shakespeare’s Romeo and Juliet , we are asked “What’s in a name? That which we call a rose / by any other name would smell as sweet.” Words and nomenclature have power a...

Perhaps one of the biggest compliance challenges facing registered investment advisors is how to create an adequate, reasonable, and enforceable policy surrounding electronic communications. The archi...

While there is no “cybersecurity rule” for SEC-registered investment advisers, the SEC does expect you to have something in place. Your policies and procedures must be “reasonably designed to identify...

December 22, 2020 saw the Securities and Exchange Commission (SEC) release its final version of the modernized Marketing Rule. This Marketing Rule replaces the Advertising and Solicitor rules under th...

In the latter half of November, the North American Securities Administrators Association published two model rules . One model rule pertained to continuing education while the second pertained to an i...