Registered Investment Advisers Archives - Page 2 of 21

Upcoming Payment Deadlines for 2022 Renewals

Posted on November 19, 2021 by admin

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

Posted on November 12, 2021 by admin

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

Posted on September 24, 2021 by admin

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

Posted on September 10, 2021September 10, 2021 by admin

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[…]

Supervising Vendors

Posted on August 27, 2021 by admin

FINRA recently released Regulatory Notice 21-29 regarding a broker-dealer’s obligation to supervise certain activities and functions of third-party vendors. This is nothing new, but we are seeing a big increase in utilizing outsourced vendors, including CRMs, Electronic Storage, Work Flow software, and IT vendors. Although the following is based on FINRA guidance for BDs, RIAs have similar responsibilities for supervising vendors, so we hope that RIA firms will glean some valuable information from this guidance as well. The level of supervision can vary depending on the vendor, access, and the critical nature of their service. Firms are encouraged to pull Read more about Supervising Vendors[…]

IRAs and Prohibited Transactions

Posted on August 20, 2021August 20, 2021 by admin

The U. S. Department of Labor (DOL) recently published their final prohibited transactions exemption regarding investment advice for ERISA plans and IRAs (PTE 2020-02). This exemption is currently effective but allows for a transition period ending 12/20/2021 for Firms to comply.