In March 2023, the Securities and Exchange Commission (“SEC”) released an alert article with some observations that they have seen when examining newly registered firms. Note that these alerts are not rules or regulations of any regulatory authority. However, investment advisory firms and broker dealers can garner many important takeaways that may assist the firm during an examination. It is important for any new firm – whether broker dealer or registered investment advisor – to start communicating and engaging with its regulatory contacts. Having an open line of communication can provide value to investment advisors and/or broker dealers in building Read more about Exam Observations for New Firms[…]
As consultants, we can’t emphasize enough the importance of having a proactive cyber security program that is specifically tailored to protect disruption of critical systems as well as protection of sensitive data for both the firm and its customers.
In November of 2020, the North American Securities Administrators Association (“NASAA”) adopted a new rule (PDF) that will require Investment Advisor Representatives (“IARs”) to complete 12 credit hours of Continuing Education annually, 6 for IAR Ethics and Professional Responsibility Requirements and 6 for IAR Products and Practice Requirements. This will be the first time IARs have been subject to Continuing Education requirements and as NASAA president Lisa A. Hopkins states, is intended to “promote heightened regulatory compliance while also helping investment adviser representatives better serve their clients by remaining knowledgeable of current regulatory requirements and best practices.” 2022 IAR CE Read more about 2022 & 2023 Continuing Education Requirements for IARs[…]
FINRA has adopted important changes to its continuing education (CE) and registration rules to train registered persons more effectively while accommodating registered persons, particularly women and underrepresented minorities, whose personal circumstances take them away from the industry for a time. Maintaining Qualifications Program FINRA has amended the CE rules to provide that beginning March 15, 2022, eligible individuals who terminate any representative or principal registration category, including any permissive registration category under Rule 1210.02, have the option of maintaining their qualification for the terminated registration category beyond the current two-year qualification period by completing annual CE through a new program, Read more about FINRA’s Changes to Continuing Education[…]
This is a reminder that December 13, 2021, is the payment deadline for Broker-Dealer, Investment Adviser Firm, Agent and Investment Adviser Representative, and Branch Renewals for 2022. Firms that miss this deadline can still make payments until 6 p.m. ET on Dec. 26, 2021, but they will be subject to a late fee. If payment is not received by Dec. 26, 2021, firms risk becoming ineligible to do business in jurisdictions where their registrations are not renewed. FINRA’s Renewal Program supports the collection and disbursement of fees related to the renewal of broker-dealer (BD) and investment adviser (IA) registrations, exempt Read more about Upcoming Payment Deadlines for 2022 Renewals[…]
This blog is a follow up to our Change to New York IAR Registration blog, and a reminder that the August 31st deadline to submit a waiver for registration to New York is looming. Effective February 1, 2021, New York now requires Individuals to register in the state. Previously, NY has not held 65/66 licenses; however, this has changed. Note the registration standards for state-registered firms and SEC-registered firms differ. State-Registered Firms The new rule requires all investment adviser representatives with more than five clients in the state of New York to register as an investment adviser, unless exempt from Read more about New York IAR Registration Waiver Deadline Reminder[…]