FINRA Notice to Members 20-08

As mentioned last week FINRA has issued Notice to Members 20-08. Here are a few of the issues that it addresses. In Notice to Members 20-08 FINRA has granted relief to member firms as they try to navigate the COVID-19 pandemic. Most importantly is the ability to set up remote offices without having to make […]

SEC Examination Priorities for 2018

Today February 7, 2018, the SEC released its Examination Priorities for 2018. Their focus this year is the retail investor. Prior areas of focus have been subcategorized under the larger retail market. Those include: electronic investment advice, fixed income execution, mutual funds and ETFs, never examined registered investment advisors, wrap accounts and municipal advisors and […]

SEC Continues Enforcement Against PE Funds

The SEC has announced another enforcement action against a PE fund adviser.  Four affiliated fund advisers of Apollo Global Management have agreed to settle an enforcement action for $52.7 million. The charges were misleading fund investors about fees and a loan agreement and failing to supervise a senior partner who charged personal expenses to the funds. […]

I Miss All the Fun

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 […]

Don’t Just Wait!

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 […]

FINRA Fails to Furnish Complete and Accurate Records

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 […]