News & Insights: Compliance Administration

SEC Requirement: Annual Amendment for Form ADV 2019

 If your fiscal year ended December 31, you will be required to file an annual amendment to your Form ADV by March 31, 2019.

FINRA Releases Report on Selected Cybersecurity Practices

On December 20, 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.

OCIE Announces 2019 Examination Priorities

On December 20, 2018, the SEC’s 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.

OCIE Issues Risk Alert Outlining New Recommendations for Electronic Communications

On December 14th, 2018, the SEC’s OCIE released a Risk Alert reminding advisers of their obligations regarding the use of electronic messaging.

Reminder: LAST DAY to Submit IARD Form Filings is December 27

The last day to submit form filings via IARD and Web CRD is Thursday, December 27.  IARD and Web CRD will be available from 5:00 a.m. until 6:00 p.m. EST.

SEC Charges Dual Registrant with Deficient Compliance Infrastructure

The SEC released an Administrative Order to Cease and Desist against a dually registered investment adviser/broker-dealer and its sole principal.  The SEC sanctioned these individuals for violations of the Investment Advisers Act of 1940 and the Securities Exchange Act of 1934.

SEC Charges Broker with “Cherry-Picking”

The SEC charged a broker with allegedly misusing client account information to allocate gainful trades into their own accounts and unprofitable trades into client retirement accounts, also known as “cherry-picking.”

SEC Charges Adviser for Failures to Disclose Conflicts of Interest

SEC released its charges against an RIA for allegedly failing to disclose the compensation it received under an agreement with a third-party broker-dealer.

RIA Settles SEC Charges for Violations of Advisers Act and Custody Rule

According to the SEC, the adviser failed to “adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act.”

Citigroup Agrees to Pay $10.5 Million for Violating Books and Records Rule and Inadequate Internal Controls

From 2013 to 2016, the SEC found that three traders of Citigroup Global Markets Inc. The SEC released its charges against Citigroup for books and records violations, inadequate internal controls and poor trade administration.

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