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Reminder: Annual Brochure Delivery Obligation

Reminder: Annual Brochure Delivery Obligation WHAT HAPPENED? Reminder: for Advisers with fiscal year-end Dec. 31, the annual brochure delivery deadline is approaching on April 30. The Adviser Act regulation (Section 275.204-3) states that Advisers must distribute, to each client and prospective client, brochures containing all information required by Form [...]

By | 2019-06-14T19:34:31+05:00 Apr 9th, 2019|Fairview® Flash Reports|

FINRA Releases Report on Selected Cybersecurity Practices

FINRA Releases Report on Selected Cybersecurity Practices WHAT HAPPENED? On December 20th, 2018, the Financial Industry Regulatory Authority (“FINRA”) released a Report on Selected Cybersecurity Practices (the “2018 Report”).  In it, FINRA outlines five topics of focus: Cybersecurity controls in branch offices; Methods of limiting phishing attacks; Identifying and [...]

By | 2019-06-14T20:24:18+05:00 Jan 23rd, 2019|Fairview® Flash Reports|

OCIE Announces 2019 Examination Priorities

OCIE Announces 2019 Examination Priorities WHAT HAPPENED? On December 20, 2018, the SEC’s Office of Compliance Inspections and Exams (“OCIE”) announced its 2019 examination priorities.  Key areas include cybersecurity, anti-money laundering (“AML”) programs, retail investors (particularly seniors), and entities providing critical market infrastructure services. Cybersecurity Cybersecurity endures as a [...]

By | 2019-06-14T20:41:16+05:00 Dec 28th, 2018|Fairview® Flash Reports|

ShareFile Accounts to Switch to Multi-Factor Authentication

ShareFile Accounts to Switch to Multi-Factor Authentication WHAT HAPPENED? The SEC’s Office of Compliance Inspections and Exams (“OCIE”) has announced that cybersecurity will continue to be a focal point for its examinations in 2019.  SEC Chairman Jay Clayton has echoed this sentiment, noting that the agency will include access controls as an [...]

By | 2019-06-14T20:29:29+05:00 Dec 28th, 2018|Fairview® Flash Reports|

OCIE Issues Risk Alert Outlining New Recommendations for Electronic Communications

OCIE Issues Risk Alert Outlining New Recommendations for Electronic Communications  WHAT HAPPENED? On December 14th, 2018, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert reminding advisers of their obligations regarding the use of electronic messaging.  Under Rule 204-2 of the Advisers Act (the “Books and Records Rule”), [...]

By | 2019-06-14T20:48:01+05:00 Dec 20th, 2018|Fairview® Flash Reports|

SEC Charges Dual Registrant with Deficient Compliance Infrastructure

SEC Charges Dual Registrant with Deficient Compliance Infrastructure WHAT HAPPENED? On December 12th, 2018, the Securities and Exchange Commission (the “SEC”) released an Administrative Order to Cease and Desist against a dually registered investment adviser/broker-dealer and its sole principal (collectively, the “Adviser”).  The SEC sanctioned these individuals for violations [...]

By | 2019-06-14T21:10:02+05:00 Dec 14th, 2018|Fairview® Flash Reports|