RCW Staff
This is a matrix for an enterprise risk management structure within a firm, courtesy of Fred Shane, former chief risk officer at Commonwealth Financial Network ...
These records should be kept 'true, accurate and current' and must be held for five years
This is an example a peer shares of a non-disclosure agreement
This is a peer's questionnaire for quizzing its subadvisers
As you dig deeper into your conflicts inventory, conduct a 'gap analysis' to identify instances where you lack policies and procedures
This Advisers Act rule addresses the delivery of Form ADV
A peer shares a copy of the firm's conflicts inventory worksheet
The Commission has even fined firms for failing to produce e-mails when the SEC has requested them
Most advisers deal with this prospect by asking the client who the adviser should turn to if these issues arise. A conservator or an attorney ...
You can pass out the flashiest compliance manuals, regularly talk adherence to the rules with staff and encourage them to bring any concerns to your ...