Historically, New York State has not required the registration of investment adviser representatives (IARs). New York has adopted regulations providing registration and examination requirements for IARS. This article focuses upon the examination and registration requirements applicable to IARs of federally covered investment
OCIE Observations: Investment Adviser Compliance Programs
On Nov. 19, 2020, the Office of Compliance Inspections and Examinations (OCIE) issued a new Risk Alert focusing on common compliance deficiencies relating to the Advisers Act and Rule 206(4)-7, otherwise known as the Compliance Rule. As a brief refresher, the Compliance
SEC Issues Additional Form CRS Guidance
On Oct. 8, 2020 the SEC issued a joint statement on additional Form CRS guidance regarding firms’ disciplinary history. The statement was released in tandem with several new FAQs, which help clarify firms’ disclosure obligations as they relate to disciplinary history. The
Dealing with Vulnerable Investors and Financial Exploitation
Unfortunately, financial exploitation is a significant and growing area of concern, particularly with elderly investors or those with diminished capacity. Investment advisers are facing a client base who is increasingly older, and with that comes the increased likelihood of an investment adviser
Sign Up
Sign up here to receive DCS Insights and Alerts and stay on top of important compliance topics that may impact your business.