5 Action Items for the New Marketing Rule for Investment Advisors
The Securities and Exchange Commission released its final version of the modernized Marketing Rule under the Investment Advisors Act on December 22, 2020.
What makes a strong FINOP?
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
SEC Issues Guidance on Form ADV Amendments – Are You Ready for October 1?
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
When Reviewing Books & Records, Don’t Forget About Data Destruction
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