Investment Management

FINRA's New Qualification and Registration Rules Effective October 1, 2018

Last month, the Securities and Exchange Commission (SEC) approved a new set of rules proposed by the Financial Industry Regulatory Authority (FINRA) intending to consolidate and simplify qualification and registration requirements for registered representatives. These rules have been long in the making by FINRA, which first filed the proposed rule change with the SEC on March 28, 2017. After ...

Calculating Regulatory Assets Under Management

A question we frequently receive from our advisory firm clients is whether they are accurately calculating and reporting regulatory assets under management ("RAUM"). RAUM, as a metric, was first introduced by the Securities and Exchange Commission ("SEC") in 2012, and must be reported on Form ADV Part 1. Correct RAUM is important for several reasons. First, RAUM is one of the factors that ...

BICE and Related Exemptions: Limiting Your Liability Until Full Implementation

Background - Transition Period May be Extended Until July 1, 2019

Cybersecurity Guidance Update from SEC

On April 28, 2015, the SEC Division of Investment Management issued guidance with regard to cybersecurity issues for both registered investment companies and registered investment advisers. (IM Guidance Update 2015-2, "Guidance"). The Guidance identifies and discusses various measures that a fund or adviser may wish to consider when addressing privacy and data risks. The SEC notes that the ...