
By Dean Pelos
Subscribe to our original industry insightsFrom the end of 2021 and into 2022, we have noticed that the SEC is paying considerable attention to how investment advisors are describing their services on Form ADV, what conflicts may exist and whether disclosed fees are reasonable.
Recent exams have shown that the SEC expects that even the smallest details need to be considered. Advisors are required to act as a fiduciary, and with Regulation Best Interest, upcoming changes to DOL requirements and the current makeup of the SEC, there has been an emphasis on justifying why advisory fees are reasonable.
We would like to share some recent examples regarding conflict disclosures that you should think about:
Even though you have your clients’ best interests at heart, it is important to make sure that they understand the nature of your services and associated costs. Regularly reviewing your disclosures can ensure that your clients are well-informed and can keep you out of trouble with regulators. Our consultants understand the nuances in word choice, reporting style and information to include for the ADV. We take the time to get input from you to ensure your disclosures are accurate, do not omit material facts and are reported correctly. Leverage our experience and resources to ensure your ADV meets the regulatory requirements and that the process receives the time this regulatory environment demands.
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