Custody

At the beginning of the year, FINRA signaled in its 2017 examination priorities letter that it has enhanced its risk-based surveillance and examination programs to ...

The staff cautions advisers to be aware that they may have custody due to the authority resulting from various agreements that may be in place ...

An investment adviser with power to dispose of client funds or securities for any purpose other than authorized trading has access to the client’s assets.[8] ...

A failure to adopt and implement compliance P&Ps reasonably designed to ensure its clients weren’t overbilled according to the terms of their advisory agreement produced ...

ITG has settled SEC charges that the New York-based broker-dealer engaged in “improper practices” involving the pre-release of American Depositary Receipts from 2011 to 2014. ...

From at least June 2008 through 2015, Brakeman knew that as BBE’s sole owner and employee, he had directed, controlled, and coordinated BBE’s activities primarily ...

From 2009 through 2015, for 15,152 advisory client accounts, MSSB inadvertently charged advisory fees in excess of what had been disclosed to, and agreed by, ...

IA Watch has learned that sources close to efforts to persuade the SEC’s Division of Investment Management to clarify if the ability for an adviser ...

IA Watch has obtained correspondence that Schwab has sent to its advisers, announcing a new policy that will begin next year to deactivate standing letters ...

Nancy Lininger, a consultant with The Consortium in Camarillo, Calif., has given us permission to share with you her template for a memo to your ...