Our blog recently discussed how soft dollar arrangements can impact the bottom line for both advisers and investors, and therefore require adequate disclosure. Other compliance requirements involve non-client facing operations, but are equally important to monitoring and protecting against conflicts
Source Code
A Compliance Guide for Robo-Advisers
The Source Code blog, published by Thompson Hine LLP, focuses on regulatory compliance and examination issues relevant to investment advisers and financial services firms. It covers topics such as responding to SEC examination requests, handling deficiency letters, remedying compliance deficiencies, and preparing for regulatory exams. The blog provides guidance on maintaining compliance programs, managing records, and understanding SEC examination priorities and processes. It also addresses practical steps for firms to improve their policies and procedures following regulatory reviews, emphasizing the importance of thorough preparation and ongoing adherence to regulatory requirements.
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Soft Dollar Arrangements – What to Know
In our last post, Craig began our discussion of trading practices by examining an adviser’s duty to obtain best execution. This post continues our trading practice discussion with a focus on soft dollar arrangements.
Soft dollar arrangements generally arise…
Meeting Your Best Execution Obligation
So, let’s say your robo-adviser firm has created a brand new strategy that you think would be attractive to investors. You’ve registered your firm, licensed your personnel, built and tested the algorithm, and now you’re ready to bring…
Maintaining Compliance with Your Portfolio Management Process
In a previous blog post, we discussed an adviser’s fiduciary duty to provide advice based on the client’s financial situation and investment objectives. In today’s post, we’ll examine the practical implications of this requirement from a compliance prospective.
Craig…
Compliance 101 – Building Your Compliance Program from the Ground Up
No Time Like the Present to Review Your Business Continuity Plan
To our readers, we hope this entry to our blog finds you and your family safe and healthy. As we all begin to envision a path forward following the unprecedented events caused by the COVID-19 pandemic, a focus on compliance…
SEC Announces Exams Will Focus on Compliance with Form CRS
If you can believe it, May 1, 2020 is almost upon us. And if you don’t remember from our February post, that is the day when advisory firms serving retail investors may start filing client relationship summaries on Form…
SEC Extends Form ADV Filing and Delivery Deadlines due to Coronavirus
As Josh discussed earlier this week, the annual update to Form ADV is generally due at the end of March for most robo-advisers. However, we are interrupting our current discussion thread to make sure you were aware that on March…
The Secret Ingredient – Disclosure of Your Algorithm
With the deadline for the annual update to Form ADV closing in at the end of March, let’s examine one aspect of Form ADV disclosure which impacts a majority, if not all, robo-advisory firms – algorithm related disclosure.
Your firm…
New Form CRS – What You Need to Know Now
OK, so remember last June when we discussed registering your firm? If you do, you may recall that the principal adviser registration document, Form ADV, is divided into two parts: Part 1 (a check-the-box form that is mostly for…
