Blog
Safeguarding Client Information
With the transition into the electronic storage of client data, Investment Advisers and Broker-Dealers are faced with more complex compliance issues regarding safeguarding client information and records. The United States Securities and Exchange Commission (“SEC”) OCIE Risk Alert from May 2019 addresses some of the issues and concerns identified with [...]
Principal and Agency Cross Trading
Investment Adviser Principal and Agency Cross Trading practices was the topic of a recent OCIE Risk Alert. The Investment Adviser’s Act Principal Transactions Section 206(3) indicates “Investment Adviser’s acting as a principal for his own account, knowingly to sell any security to or purchase any security from a client, or [...]
Compliance, Supervision, and Disclosures
Beginning in 2017, the United States Security and Exchange Commission (“SEC”) initiated a series of examinations aimed at compliance policies and procedures regarding individuals within these firms that had a prior disciplinary history. […]
Regulation Best Interest and CRS Relationship Summary
In June, the U.S. Securities and Exchange Commission (SEC) passed “Regulation Best Interest: The Broker Dealer Standard of Conduct” and “Form CRS Relationship Summary; Amendments to Form ADV”. This legislation, Regulation Best Interest and CRS Relationship Summary, is the cumulation of many attempts to mesh the “fiduciary standard” for Investment [...]
Custody of Cryptocurrency: Considerations for Broker-Dealers
It is evident that the U.S. Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) are constantly putting efforts forward to navigate the unchartered waters of cryptocurrency. Just days before Blockstack’s Reg A+ token offering received SEC approval, the SEC and FINRA issued a joint statement to provide [...]
Cryptocurrency Reg A+ Offering Approved by the SEC
Last month, the U.S. Securities and Exchange Commission (SEC) finally gave a blockchain startup company, Blockstack, approval to sell bitcoin-like digital tokens directly to investors— to some extent. The SEC has previously sued and fined several cryptocurrency companies for initial coin offerings (ICO) that the agency said violated securities law. [...]