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[…]

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[…]

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[…]

Supervising Vendors

Supervising Vendors

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[…]

New York IAR Registration Waiver Deadline Reminder

New York IAR Registration Waiver Deadline Reminder

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[…]