Tag Archive: Core

Course Description: Compliance professionals must be ever mindful of the ongoing mandates embodied in Rule 206(4)-7 under the Investment Advisers Act and Rule 38a-1 under the Investment Company Act to maintain, review, test and modify written compliance policies and procedures that are reasonably designed to detect violations and weaknesses in internal controls and compliance systems. […]

The SEC’s anti-fraud rules pursuant to Section 206 of the Investment Advisers Act of 1940 lay the regulatory foundation of the adviser’s relationship with its clients.

Course Description: In 1963, the United States Supreme Court held in SEC v. Capital Gains Research Bureau, Inc., that Section 206 of the Investment Advisers Act of 1940 imposes a fiduciary duty on investment advisers by operation of law. Section 206 of the Act (generally referred to as the “anti-fraud” provision) makes it unlawful for […]

Course Description: The ongoing insider trading investigations and civil and criminal enforcement actions involving Wall Street professionals is a reminder of the importance of an investment adviser having effective policies and procedures to detect and prevent the misuse of material nonpublic information. This mission-critical topic will be a focal point of the course. Section 204A […]

Course Description: Ethics is not an option; it’s a requirement. Since the adoption of the SEC Rule on Codes of Ethics, every registered investment adviser firm must adopt codes of ethics that establish standards of conduct and address conflicts that arise from personal trading issues. Many state advisers have also adopted a code of ethics […]

Course Description: For the average investment adviser, the prospect of managing the administrative and compliance aspects of the daily operations of the firm can be daunting. This pressure is further multiplied by recent regulatory trends and enforcement actions. Given these trends, advisers need to be particularly concerned about the accuracy, quality, and completeness of the […]

Investment adviser advertising continues to be one of the top problem areas identified by the SEC.

Five years ago the SEC approved a new Form ADV Part 2, a “plain English” narrative approach to client disclosure, which was put into effect in 2011.

Inaccurate and/or inadequate Form ADV disclosures are consistently cited in the SEC’s and many states’ list of “Top Deficiencies.”

Course Description: Understanding the intricacies and implications of the Investment Advisers Act of 1940 (Advisers Act) is fundamental to the core responsibilities of any investment adviser compliance professional. A section-by-section review of the Advisers Act brings renewed focus to the root source of each requirement, many of which are likely to be encountered in compliance […]