Happy New Year to all and Welcome to Thompson Hine’s newest blog offered as a service to those in the investment management and broker-dealer communities.
What a better way to begin this blog then discussing the problems that arise for
The exam is finally over! If your advisory firm has been undergoing an SEC examination, you’ve probably been waiting a long time to utter those words. Well, time to get back to business, right? Not so fast. As our series
An onsite examination from the SEC can often feel like a surprise visit from your in-laws. You wish you had more time to clean up before they arrived, you know they’re judging you the whole time they’re there, and you
In our last episode Don’t Panic, Josh walked through how to respond to an initial examination letter, including a handy checklist of items that roboadvisors should always have in good order. But what if your existing practices don’t cover
You open your inbox, ready to start your day, and what’s the first thing that greets you? A notice that you’re being examined from the SEC’s Division of Examinations (EXAMS), along with an initial request list for information. Time to
So you’ve built your robo-adviser, registered it, hired and licensed personnel, implemented a compliance program, conducted a successful marketing campaign, and (finally) gotten to do what you’ve really wanted to do the whole time – advise clients and manage portfolios.
For nearly a decade now, regulators have placed the Chief Compliance Officer (“CCO”) squarely within the sights of enforcement, on the logic that holding CCO’s individually liable for violations would prompt robust compliance programs, and deter lackluster supervision. The reasonableness of such
You probably don’t need to be convinced that information security is critically important. But just in case you do, you should know that the U.S. Securities and Exchange Commission (SEC) continues to emphasize the importance it places on information security.
As Marc mentioned last time, the SEC’s Division of Examinations’ (EXAMS) has made it a priority in 2021 to review the steps that firms take to ensure information security and operational resiliency. For robo-advisers, given that they conduct so much
We continue our discussion of the SEC’s Division of Examinations’ (EXAMS) 2021 Priorities (see here) with an overview of information security and operational resiliency. The daily drumbeat of cyber-intrusion incidents is certain to keep cybersecurity at the