Cash Solicitation

Proposal would rename old rule, keep some elements and change others

Commission proposing tweaking record-keeping rule in light of advertising proposal

Cetera has paid cash fees to approximately 350 banks to, among other things, solicit investment advisory clients on behalf of Cetera. As part of this ...

For the first time in two years, OCIE’s 2019 exam priorities letter didn’t call out robo-advisers as a key focus (IA Watch, Jan. 2, 2019). ...

It’s difficult to confuse the plain dictates of the cash solicitation rule, Advisers Act rule 206(4)-3, yet it seems some advisers have done just that. ...

This Risk Alert includes observations by OCIE staff and is intended to assist investment advisers in identifying potential issues and adopting and implementing effective compliance ...

Among the plethora of changes you face in updating your new Form ADV, Part 1 you’ll find two items that zero in on your payment ...

John Rafal, Essex’s then President and CEO, and Peter Hershman, a Connecticut attorney, fraudulently schemed to circumvent the rule regarding payments for client solicitations. Rafal ...

Rafal became concerned that his clients and others had heard rumors about him, including that Rafal was under investigation for engaging in a securities law ...

In an ideal world, compliance and accounting would be linked when it comes to paying solicitors like July and fireworks are intertwined.   But perfection ...