The Securities and Exchange Commission released its final version of the modernized Marketing Rule under the Investment Advisors Act on December 22, 2020.
FINRA requires all broker-dealers to designate a Principal Financial Officer (PFO), Principal Operations Officer (POO) and a Financial and Operations Principal (FINOP). Each of these positions must have passed the appropriate licensing exam to be registered as a Financial and Operations Principal (Series 27 or 28), depending on the broker-dealer’s business. In small firms, these… READ MORE
October 1 is the date that RIAs must comply with the August, 2016 amendments to the Form ADV. This month the SEC issued guidance around how a filer making an unanticipated, other-than-annual amendment should respond to the new or amended items in Item 5 and related Schedule D sections. Some advisors have indicated to the… READ MORE
The beginning of a new year is often when compliance officers assess whether the firm is meeting basic compliance requirements. Whether it is part of your annual 206(4)-7 or 3120 testing, making sure your records are in order is a basic requirement. Many firms retain records long past their regulatory requirements. When asked, firms often… READ MORE