7 Things Advisers Must Do To Avoid Custody
By Scott on May 16, 2017 in Compliance
A recent SEC No-Action Letter (Investment Adviser Association, February 21, 2017) clarified …
3 Keys to Reducing Potential SEC Penalties
By Scott on May 10, 2017 in Regulatory Environment
One day you might find yourself in a situation where you have …
SEC Cybersecurity Exam Requests
Cybersecurity seems to be all the rage with both SEC and state …
SEC Issues Guidance Re: Inadvertent Custody
By Scott on March 1, 2017 in Compliance
Maybe there is something wrong with a rule that needs continual guidance? See …
3 Most Typical Books & Records Rule Deficiencies
By Scott on February 17, 2017 in Compliance
Below are three typical examples of deficiencies or weaknesses with respect to …
The 4 Most Typical Code of Ethics Violations
By Scott on February 16, 2017 in Compliance
As stated in the recent SEC Risk Alert, four typical code of ethics …
Top 3 Custody Rule Deficiencies
By Scott on February 15, 2017 in Compliance
As stated in the recent SEC Risk Alert, the 3 most frequent custody issues identified …
Top 4 Regulatory Filing Deficiencies
By Scott on February 14, 2017 in Compliance
As stated in the recent SEC Risk Alert, the 4 most frequent …
Top 4 Compliance Program Deficiencies
By Scott on February 13, 2017 in Compliance
As stated in the recent SEC Risk Alert, the 4 most frequent …
5 Most Frequent Compliance Topics Identified in Investment Adviser Exams
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) identified the following five …
SEC 2017 Examination Priorities
The SEC’s Office of Compliance Inspections and Examinations has published its examination …
FAQs: Best Execution
These FAQs are part of a series of frequently asked questions that …
Adviser Fined $25,000 for Failure to Conduct Annual Review
By Scott on October 24, 2016 in Uncategorized
Dupree Financial Group, LLC, an investment adviser registered with the SEC, was …
FAQs: Suitability
These FAQs are part of a series of frequently asked questions that …
Entrepreneur Magazine Gives CCO Companion Thumbs Up!
Visit an app marketplace and search for parenting or management apps, you …
FAQs: Insider Trading
These FAQs are part of a series of frequently asked questions that …
8 Types of SEC Enforcement Actions
By Scott on April 14, 2016 in Compliance
In the past year there have been eight general types of SEC Enforcement …
FAQs: Solicitors
These FAQs are part of a series of frequently asked questions that …
CCO Companion Release 1.2 in App Store Today!
In addition to updating the Reference Library with all relevant Q1 2016 …
The 6 Attributes of a Competent CCO
By Scott on April 10, 2016 in Compliance
While we could probably list dozens of attributes that a competent chief …
5 Ways Advisers Fail to Realize they Have Custody
By Scott on April 9, 2016 in Compliance
The SEC Staff had observed failures by investment advisers to realize that …
3 Sure Ways to Get Slammed During an SEC Audit
By Scott on April 8, 2016 in Regulatory Environment
As the saying goes, the only sure things in life are death …
New DOL Fiduciary Rule
By Scott on April 8, 2016 in Compliance
This past Wednesday (April 6, 2016) the Department of Labor (DOL) issued a pre-publication …
Performance Advertising – 6 Common Mistakes
By Scott on April 5, 2016 in Compliance
Inaccurate performance claims and advertising violations are always in the top 3 …
Users Guide – Exam Prep
By Scott on March 30, 2016 in User's Guide
This User’s Guide is designed to help you prepare for an …
FAQs: Performance Advertising
These FAQs are part of a series of frequently asked questions that …
User’s Guide – Annual Review
By Scott on March 28, 2016 in User's Guide
This User’s Guide is designed to help you complete your annual compliance …
10 Most Common Deficiencies Found by SEC Examiners
By Scott on March 25, 2016 in Compliance
I was clearing out some old folders on my computer the other day …
The Reviews Are In and CCO Companion is a Smash Hit!
The response has been absolutely terrific! See what your colleagues are saying …
FAQs: Pay-To-Play
These FAQs are part of a series of frequently asked questions that …
3 . . 2 . . 1 . . Blast Off!!!
By Scott on March 21, 2016 in Countdown to Launch
Today CCO Companion has launched into the stratosphere! Well, at least into …
FAQs: Directed Brokerage
These FAQs are part of a series of frequently asked questions that …
Using Enforcement to Teach Compliance
By Scott on March 11, 2016 in Regulatory Environment
In an earlier post (Dec. 16, 2015), we discussed how enforcement actions …
FAQs: Advertising
These FAQs are part of a series of frequently asked questions that …
March Madness
By Scott on March 7, 2016 in Compliance
No, not the NCAA tournament, but rather, the rush to get your …
CCO Fined $1 Million
By Scott on March 4, 2016 in Regulatory Environment
That ain’t no typo.
FAQs: Trade Aggregation and Allocation
By Scott on March 2, 2016 in Compliance
These FAQs are part of a series of frequently asked questions that …
Top SEC Exam Deficiencies
By Scott on February 29, 2016 in Regulatory Environment
The assistant director of the SEC’s Office of Compliance, Inspections and Examinations (OCIE) …
Random Friday Musings
By Scott on February 26, 2016 in Compliance
Ahhh Friday – the perfect day for a random assortment of insights. …
FAQs: Annual Review
These FAQs are part of a series of frequently asked questions that …
