“Have you kept up with the pace of regulatory change?” asked the SEC official. Your compliance P&Ps should “reflect those regulatory changes”
As with any compliance issue, your work begins with a risk assessment. You may determine your risks are so small as to justify only a modest ...
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The SEC’s Division of Examinations third risk alert of the year reminds advisers to include their branch offices in their compliance P&Ps, especially those designed ...
A greater understanding of what it takes to comply with the SEC’s best interest standard comes out of new staff guidance designed to help advisers ...
IAA states that the Division of Examinations could simply release a risk alert with guidance to help advisers improve their oversight of vendors without a ...
“It is getting more complicated” to search for conflicts because of business complexity
Still no sign that a widely anticipated SEC sweep looking at compliance with the new advertising rule has commenced. Yet examiners are asking lots of ...
Lack of communication between robo adviser's compliance personnel and engineers contributes to disclosure issues
Form ADV responses reveal a chill in using the new ad rule’s flexibility