Books and Records

Beginning last fall, the SEC launched a sweep exam into whether fees paid by mutual funds to sub-transfer agents and others are really disguised reimbursement ...

Dually-registered firms that have customers that are receiving both brokerage and investment advisory services could simplify their record retention practices for those accounts by applying ...

Younger generations of investors embrace texting. How can you possibly tell a client you won't communicate via his preferred method

How would you feel if this happened to you? David Nosal left his employer but then persuaded former colleagues to log into the company's computer ...

This is a records retention and document destruction policy courtesy of Michelle Jacko, CEO of Core Compliance & Legal Services in San Diego.

Many firms lump their policy disclosures to clients when they offer their annual Form ADV, Part II. Be careful. Some firms forget to include a ...

The SEC has joined with seven other federal agencies to offer a Web site you can use to construct the appropriate privacy notice for your ...

Some suggest that a best practice would be to keep such logs in a WORM format - write once, read many - which doesn't allow ...

The SEC has expanded the ability of investment advisory firms to rely on a third-party to produce required records in a new no-action letter in ...

    Investment Advisers Act of 1940 — Rules 204-2(a), (b) and (g) Omgeo LLC August 14, 2009   RESPONSE OF THE OFFICE OF CHIEF ...