Gemmer Asset Management permits IA Watch to share with you its cybersecurity policy related to access to client information.
A peer shares a copy of the RIA's SEC document request letter from a 2015 exam out of the SEC's New York Regional Office.
A peer shares an example of a form that provides details of a cross trade.
This one stemmed from an OCIE exam launched in 2015.
This is an example of an SEC exam document request letter sent to an investment advisory firm. It asks for many items, including disclosures about ...
This letter comes from an SEC exam launched in 2015 from the SEC's Los Angeles Regional Office.
This chart shows how to present past-specific recommendations in line with the SEC's TCW no-action letter.
A peer shares an example of his firm's "scorecard" for judging which brokers to use under its best execution policy.
A peer, Mario Hernandez, CFP®, director of operations Gemmer Asset Management ($568M in AUM) in Walnut Creek, Calif., shares an Excel file that displays his ...
This risk alert, from November 2015, centers on advisers that rely upon outsourced CCOs. It flags behaviors these CCOs should avoid, based on what was ...