Blog
Large Trader – Rule 13h-1 (Part 1)
Rule 13h-1 helps the SEC identify and obtain trading information on market participants that conduct a substantial amount of trading activity in the U.S. securities market. The rule imposes filing requirements on persons that meet the definition of “large trader.” A larger trader is any person that directly or indirectly, [...]
Annual Reviews – SEC Rule 206(4)-7
SEC Rule 206(4)-7 requires investment advisers to review, no less frequently than annually, the adequacy of its written compliance policies and procedures and the effectiveness of their implementation. The SEC expects annual reviews to take into consideration any compliance matters that arose during the previous year, any changes in the [...]
Order Audit Trail System (OATS)
Established by FINRA, the Order Audit Trail System (OATS), is an integrated audit trail of order, quote and trade information for all NMS (National Market System) stocks and OTC equity securities. As part of FINRA’s surveillance activities, Rules 7400 through 7470 (OATS Rules) and Rule 4554, OATS requires electronic auditing [...]
FinCEN vs. OFAC
What is the difference between FinCEN and OFAC? Both organizations are bureaus of the U.S. Treasury department; however, FinCEN requires searches for suspected criminals and OFAC searches identify known criminals. […]
Wrap Fee Program
A wrap fee program is an arrangement between financial institutions (typically broker-dealers and investment advisers) that enables customers to pay an all-inclusive fee (usually as a percentage of assets) for investment advisory services bundled with various other services, such as execution, clearing, and custodial services. These programs can be referred [...]
Investment Advisers: SEC vs. State Registration
Due to the Dodd-Frank legislation, as of mid-2012, there are rules for registration eligibility that are primarily determined by a firm’s assets under management (“AUM”). For all firms below $100 million AUM, registration is required with the appropriate state jurisdictions. For firms above $100 million AUM, registration will be at [...]