Earlier this week I told investment advisers CCOs not to lose sleep. I suggested that during this 45 day period until registration you should systematically review your compliance and supervisory policies and procedures. I missed the fun yesterday. Yesterday at the Investment Adviser Association Investment Adviser Compliance Conference Robert Plaze, Deputy Director of the SEC Division of Investment Management warned […]
So you got your Form ADV filed with the SEC and you are waiting for March 31. Don’t just wait. As I wrote back in December registration is just the beginning of the journey. Now is the time to find the kinks in your compliance and supervisory programs. Over the next month you should systematically […]
Davison-LawBlog wishes you a Happy New Year. This is going to be an interesting year in the financial services/capital markets world. New regulatory rules will keep us busy as well as watching the presidential elections. I am looking forward to settling into my new position as Of Counsel at Richardson & Patel and continuing to […]
If you are the Chief Compliance Officer for a broker-dealer and a registered investment advisor keep reading. During 2011, one within the last month, the SEC has taken action against two dually registered broker dealer/investment advisers for failure to have adequate written supervisory policies and procedures, compliance manuals and code of ethics for the advisory […]
This headline flashed across my computer screen a few days ago in an e-mail. SEC orders FINRA to improve compliance policies and procedures The SEC order arises from a whistleblower complaint. Prior to submitting records to the SEC, the regional director of the FINRA Kansas City office had minutes of the district office staff […]
Last week in my post on the Startup Exemption I wrote about hearings starting in Congress. Having reviewed the startup exemption proposal that is presently circulating on the Internet and reading some of the testimony from last week’s hearings I realize what the main problem it is not the concept of the startup exemption. It […]
In the last few weeks I found crowd investing. The SEC got there before me in its case dealing with an attempt to buy a beer company with investments being made on a website. I’m not sure why I have been so taken by this concept. Most of my career has been spent working in […]
The SEC has issued a request for comment on Review of Existing Regulations. This request comes according to the SEC, based upon the “dynamic and fast-moving” financial markets. It also comes because President Obama issued an order in July that all regulatory agencies might consider a review of rules that might be “outmoded, ineffective or […]
Perhaps I spent too much time this weekend sitting in my apartment listening to the news and weather reports about the approaching hurricane, but on Sunday after the warnings were lifted and family and friends were safe, with the exception of a few power outages, I started to think about the similarity between the preparation […]
I am not aware of many broker-dealers that do not have, some, if not all of the operational professionals at senior levels registered. But clearly my experience did not spread across the entire industry. In case you missed the release (Reg. Not. 11-33) while you were away on vacation, effective October 17, 2011 certain operational […]
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