Conflicts of Interest

OCIE encourages advisers, when designing and implementing their compliance and supervision frameworks, to consider the risks presented by hiring and employing supervised persons with disciplinary ...

Don’t just take the word of any applicant about the person’s disciplinary history. Investigate whether the person’s being honest about past troubles.   This is ...

In an April speech, OCIE Director Peter Driscoll detailed five of his division’s exam priorities and core risk areas (IA Watch, May 9, 2019). An ...

On Behn’s recommendation, approximately 40 of Behn’s advisory clients invested more than $7 million in securities issued by Aequitas Commercial Finance, LLC (“ACF”), one of ...

The good news is that the recently adopted Form CRS has been further condensed to a maximum two-page disclosure document for investment advisers and broker-dealers ...

xaminers have frequently observed deficiencies with respect to the custody rule, and in 2017, OCIE issued a Risk Alert identifying some of the typical deficiencies ...

Many would say only having four to five hours’ worth of telephone calls and performing a few Google searches doesn’t constitute sufficient due diligence before ...

As the investment adviser to both the seller and buyer of a commercial real estate asset, Tamlico had a clear conflict. When the New York-based ...

Peterson and his former colleague, James Polese, with securities fraud for engaging in various schemes to defraud their clients, including fraudulently misappropriating $350,000 of their ...

BB&T Investment Services failed to disclose sufficient facts to enable clients to determine that the compensation arrangement between BB&T Investment Services and the Affiliated Adviser ...