NASAA Reveals Top Investor Threats for 2022

NASAA Reveals Top Investor Threats for 2022

On January 10, 2022 the North American Securities Administrators Association (NASAA) released its annual list of top investor threats for 2022 and urged caution before purchasing popular and volatile unregulated investments – especially those involving cryptocurrency and digital assets. NASAA also announced guidance for investors, including steps to take to protect from fraud in the new year. “The most common telltale sign of an investment scam is an offer of guaranteed high returns with no risk. It is important for investors to understand what they are investing in and with whom they are investing,” said Melanie Senter Lubin, NASAA President Read more about NASAA Reveals Top Investor Threats for 2022[…]

Our Top 5 Blogs of 2021

Our Top 5 Blogs of 2021

MasterCompliance continues to provide clients and the public with guidance on industry focus areas, new rules, compliance foundations, and regulatory priorities. This blog explores our top 5 blogs of 2021. 1. Form ADV Part 2B: Disclosures for Supervised Persons Form ADV Part 2B is a brochure supplement that must contain certain information about specific individuals, acting on behalf of the investment adviser, who actually provide the investment advice and interact with the client. The brochure supplement is also a narrative format in plain English and includes six required disclosure categories, with a seventh for advisers registered or are registering with Read more about Our Top 5 Blogs of 2021[…]

Upcoming Payment Deadlines for 2022 Renewals

Upcoming Payment Deadlines for 2022 Renewals

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[…]

DOL Delay: IRAs and Prohibited Transactions

DOL Delay: IRAs and Prohibited Transactions

Earlier this year, the U. S. Department of Labor (DOL) published their final prohibited transaction exemption regarding investment advice for ERISA plans and IRAs (PTE 2020-02). This exemption is currently effective but allowed for a transition period ending 12/20/2021 for Firms to comply. The DOL recently announced a temporary enforcement policy on the new rule. After listening to the feedback of many financial institutions that doing an off-cycle, mass mailing is very cost prohibitive, they agreed to extend the implementation start date to January 31, 2022. The DOL will not pursue claims against investment advice fiduciaries who are working diligently, Read more about DOL Delay: IRAs and Prohibited Transactions[…]

Website Reviews

Website Reviews

Firms should have appropriately established controls for review, approval, and archiving of all firm related websites and related content. Firms must be able to readily produce all current and historical website content that promotes the firm or any of its covered persons. The firm should establish controls to ensure that all content is approved prior to use by a designated supervisor. Such supervisor is to have appropriate knowledge related to such content requirements. The guidelines below do not represent an exclusive list of considerations that a supervisor must make in determining whether such website complies with all applicable standards. Content Read more about Website Reviews[…]

Personal Trade Reviews

Personal Trade Reviews

Citigroup Global Markets Inc. was recently censured and fined $350,000.00 ([PDF] FINRA Case #2019064316401) for failing to have a supervisory system to ensure statements were reviewed timely, as well as not ensuring they were receiving paper statements for accounts at custodians for which they did not have a direct feed. Although this particular incident was a BD fine, this information should be helpful for RIAs as well. An RIA should be conducting personal trade reviews as a part of their Code of Ethics. Considerations The review and supervision of outside brokerage accounts isn’t news; however, it’s important to take a Read more about Personal Trade Reviews[…]