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Annual Reviews for State Registered RIAs
Investment advisers should review, no less frequently than annually, the adequacy of its written compliance policies and procedures and the effectiveness of their implementation. The states expect annual reviews to take into consideration any compliance matters that arose during the previous year, any changes in the business activities of the [...]
Code of Ethics for Registered Investment Advisers
All advisers registered with the SEC must adopt and enforce a written code of ethics reflecting the adviser’s fiduciary duties to its clients. The firm’s code of ethics is required to meet minimum standards to appropriately address conflicts of interest identified by the firm. To ensure compliance with the code [...]
Exclusions from Registration as an Agent
Agents are individuals in a sales capacity who represent broker-dealers or issuers of securities. As agents, they act, usually on commission basis, on behalf of others. Agents are often referred to as registered representatives, whether sell registered securities or securities exempt from registration. The use of the term individual here [...]
Outside Business Activities for RIAs
Outside Business Activities (“OBAs”) of individuals can create potential conflicts of interests with the registered investment advisers that employ them. Advisors are responsible for providing written notice before they act as an employee, independent contractor, sole proprietor, officer, director or partner of another person; or receive compensation or have the [...]
What Should an RIA’s Training Plan Cover?
Registered investment advisers (“RIAs”) should ensure training is assigned periodically to keep covered persons up to date on industry and product related topics. In planning, developing, and implementing an RIA’s training plan, firms should consider its size, structure, and the scope of its business activities, as well as any regulatory [...]
Agent Registration Process
The USA defines an agent as any individual who represents a broker-dealer or an issuer in effecting or attempting to effect transactions in securities for their clients. Agents are individuals in a sales capacity who represent broker-dealers or issuers of securities. Any person who meets the definition of an agent [...]