RIA Compliance and Practice Management Blog

The DOL Fiduciary Rule for RIA Firms: Where it Stands Today

Posted by RIA in a Box

Mar 20, 2017 8:44:59 AM

DOL has delayed the applicability date of the DOL fiduciary rule for RIA firmsAs of today, compliance with the Department of Labor ("DOL") fiduciary rule is still scheduled to be required on April 10, 2017. However, there are a number of recent developments that have already delayed the rule's applicability date in "practice" and more to come shortly that will likely "officially" delay the rule's implementation date. In this latest blog post, we take a look at recent events impacting the rule's future including President Donald Trump's memorandum seeking a review of the rule, a proposal submitted by the DOL to delay the rule's applicability date, and a temporary enforcement policy field assistance bulletin issued by the DOL. Last week, in our latest client webinar on the fiduciary rule, we advised all of our registered investment adviser ("RIA") firm clients to continue to prepare to comply with the rule but to wait to implement any changes until there is more clarity. 
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Topics: RIA Compliance

Top RIA Compliance News Articles for the Week of March 11, 2017

Posted by RIA in a Box

Mar 17, 2017 12:40:56 PM

IAA DOL fiduciary rule delay and 3rd party audits

Each week we’re giving you our weekly report highlighting the top compliance news articles from various industry news publications. We have selected the most relevant and important news articles related to registered investment adviser ("RIA") compliance and regulatory issues. This week's recap focuses on the current status of the Department of Labor ("DOL") fiduciary rule. Check back each week for the latest list of top stories.

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Topics: RIA Compliance

2017 Form ADV Annual Updating Amendment Deadline is March 31, 2017

Posted by RIA in a Box

Mar 14, 2017 9:36:00 AM

2017 RIA Form ADV renewal deadline is March 31, 2017All registered investment adviser ("RIA") firms, whether registered at the federal or state level, need to file this year's required Form ADV amendment within 90 days of the firm’s fiscal year-end (generally March 31, 2017 with a traditional December 31, 2016 fiscal year end date). Even if an RIA firm was first registered in late 2016, the investment advisory firm is still required to file annual Form ADV updating amendment on March 31, 2017 if the firm has a traditional December fiscal year-end. Failure to file the required annual amendment can result in serious regulatory issues.

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Topics: RIA Compliance

Top RIA Compliance News Articles for the Week of March 4, 2017

Posted by RIA in a Box

Mar 10, 2017 1:42:55 PM

IAA DOL fiduciary rule delay and 3rd party audits

Each week we’re giving you our weekly report highlighting the top compliance news articles from various industry news publications. We have selected the most relevant and important news articles related to registered investment adviser ("RIA") compliance and regulatory issues. This week's recap focuses on the Department of Labor ("DOL") fiduciary rule delay, more targeted Securities and Exchange Commission ("SEC") exams for RIA firms, and a looming anti-money-laundering ("AML") rule. Check back each week for the latest list of top stories.

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Topics: RIA Compliance

SEC Issues Regulatory Compliance Guidance for Online Robo Advisers

Posted by RIA in a Box

Mar 6, 2017 9:10:00 AM

SEC regulatory guidance for online robo advisorsOn February 23, 2017, the Securities and Exchange Commission ("SEC") Division of Investment Management released new regulatory compliance guidance related to automated online advisers more commonly referred to as "robo advisers." The detailed guidance highlights that, "robo advisers, like all registered investment advisers, are subject to the substantive and fiduciary obligations of the Investment Advisers Act of 1940 (the “Advisers Act”)," and zeroes in on three particular regulatory compliance areas that such automated investment advisers should be focused on properly addressing. This latest guidance follows recent SEC staff guidance released in January announcing that the robo adviser business model would be a registered investment adviser ("RIA") 2017 regulatory examination focus area

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Topics: RIA Compliance

Top RIA Compliance News Articles for the Week of February 25, 2017

Posted by RIA in a Box

Mar 3, 2017 10:37:46 PM

IAA DOL fiduciary rule delay and 3rd party audits

Each week we’re giving you our weekly report highlighting the top compliance news articles from various industry news publications. We have selected the most relevant and important news articles related to registered investment adviser ("RIA") compliance and regulatory issues. This week's recap focuses on the Department of Labor ("DOL") fiduciary rule delay and third party exams for RIA firms registered with the Securities and Exchange Commission ("SEC"). Check back each week for the latest list of top stories.

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Topics: RIA Compliance

SEC Issues RIA Standing Letter of Authorization (SLOA) Custody Guidance

Posted by RIA in a Box

Feb 27, 2017 8:25:21 AM

RIA SLOA SEC Custody Issues and GuidanceOn February 21, 2017, the Securities and Exchange Commission ("SEC") Division of Investment Management issued a no-action letter in response to a letter from the Investment Adviser Association ("IAA") asking for clarification and assurances related to Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). In particular, the IAA sought to 1) confirm that a registered investment adviser ("RIA") firm "utilizing a standing letter of instruction or other similar asset transfer authorization arrangement established by a client with a qualified custodian ('SLOA')" would not be deemed to have custody and 2) that SEC staff would not recommend enforcement action under Section 206(4) of the Advisers Act and the Custody Rule against an RIA firm if it acts pursuant to a SLOA, as described in the IAA's letter, without the advisory firm obtaining a surprise independent verification (“surprise examination”) as required by Rule 206(4)-2(a)(4).

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Topics: RIA Compliance

Top RIA Compliance News Articles for the Week of February 18, 2017

Posted by RIA in a Box

Feb 24, 2017 3:17:38 PM

SEC regulatory compliance guidance on SLOAs and robo advisers

Each week we’re giving you our weekly report highlighting the top compliance news articles from various industry news publications. We have selected the most relevant and important news articles related to registered investment adviser ("RIA") compliance and regulatory issues. This week's recap focuses on new guidance issued by the Securities and Exchange Commission ("SEC") in regards to a potential custody issue and robo advisers. Check back each week for the latest list of top stories.

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Topics: RIA Compliance

New RIAs should be Cautious using 120 Day SEC Registration Exemption

Posted by RIA in a Box

Feb 21, 2017 1:02:15 PM

SEC new RIA 120 day registration exemption information

Recently, we've seen an increasing number of newly formed registered investment adviser ("RIA") firms rely on the Rule 203A-2(c) exemption which allows an RIA firm to register initially with the Securities and Exchange ("SEC") if it has "a reasonable expectation that it would be eligible to register with the Commission within 120 days after the date the investment adviser's registration with the Commission becomes effective." According to the latest SEC registration statistics as of February 1, 2017, of the 12,258 firms currently registered at the federal level, 184 firms are presently relying on this exemption as the basis for registration. 

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Topics: RIA Operations, RIA Compliance

Top RIA Compliance News Articles for the Week of February 11, 2017

Posted by RIA in a Box

Feb 17, 2017 4:25:41 PM

RIA options for errors and omissions insurance, cybersecurity insurance, and fidelity and financial instution bonds

Each week we’re giving you our weekly report highlighting the top compliance news articles from various industry news publications. We have selected the most relevant and important news articles related to registered investment adviser ("RIA") compliance and regulatory issues. This week's recap focuses on the significant announcement that the implementation of the Department of Labor ("DOL") fiduciary rule has been potenetially delayed and there is a new nominee for DOL Secretary of Labor. Check back each week for the latest list of top stories.

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Topics: RIA Compliance

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