The SEC has been watching wrap fee programs for quite a while. From 2017-19, the SEC’s annual examination priorities named wrap fee programs as putting investors at risk. The SEC’s Division of Examinations (Division) released a July 21, 2021 Risk Alert with guidance from examiners during its Wrap Fee Initiative. The Risk Alert, “Observations from Examinations of Investment Advisers Managing Client Accounts That Participate In Wrap Fee Programs,” contains compliance guidance for Registered Investment Advisers (RIAs) that recommend wrap fee
Read MoreSEC Charges 21 RIAs for Form CRS Filing and Delivery Failures
On July 26, 2021, the SEC announced that 21 Registered Investment Advisers (RIAs) settled charges alleging that they failed to file and deliver their client relationship summaries, known as Form CRS, in a timely manner. Form CRS is also frequently referred to as Form ADV Part 3. Six broker-dealers were also accused of not filing or delivering their client relationship summaries. On June 5, 2019, the SEC adopted Form CRS and required SEC-registered investment advisers and SEC-registered broker-dealers to file
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New York Regulatory Update
The New York State Department of Law (the “Department”) recently adopted new regulations that went into effect on February 1, 2021. These new regulations govern the registration and examination requirements for investment adviser representatives domiciled in New York, or doing business with New York clients. Previously, New York did not require registration of state and SEC investment adviser representatives. The Department is allowing for an implementation period for current New York domiciled representatives to apply for registration by August 31,
Read MoreRIAs Can Expect Big Changes with SEC’s New Marketing Rule
Guest post by Ara Jabrayan On December 22, 2020, the SEC enacted the new Marketing Rule, which will have an enormous impact on Registered Investment Advisers (RIAs). The new rule will replace the prior Advertising Rule, as well as the Cash Solicitation Rule. The SEC also amended Form ADV and the Books and Records Rule to implement changes resulting from the Marketing Rule. The SEC enacted the new Marketing Rule to protect investors from misleading advertisements and solicitations, while accommodating
Read MoreAwesome Compliance Software: Mission Accomplished
Since our inception in 2016, SmartRIA’s mission has been to be the best software company in the world at simplifying compliance for wealth managers. It’s a tall order, but one that we believe is incredibly important, as wealth managers have significant regulatory burdens that need to be made achievable, while also ensuring the regulations’ purpose is maintained: the protection of our personal wealth. Towards this end, we have been working across 3 fronts: Solving more and more compliance problems inside
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Growing Your Firm in Any Season (While Maintaining Trust and Compliance)
In this article, Blain Wease, President of Provincial Development Group, and Mac Bartine, CEO of SmartRIA, explore the 5 dimensions of growth and how a culture of compliance can help to support and organize execution of those dimensions. We’ll be exploring these in depth in our upcoming webinar. Growing Your Firm in Any Season The skill sets required to grow any business share dimensions from both art and science, and wealth management firms are no exception. We typically find one
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Compliance in the Age of Pandemics
The COVID-19 pandemic has been a catalyst for dynamic change for advisor businesses in all but one area – the ongoing and inexorable march of regulation and compliance. Many regulatory deadlines and expectations have not been deflected by the real-world chaos that advisory firms are dealing with. A quick breather and a situational analysis on this front can be helpful. To get a better sense of the regulatory environment amidst this pandemic, we decided to check in with Institute founding
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7 Easy Steps to RIAs Working Remotely Without Cybersecurity Risk
When we’re all still stuck at home due to the COVID 19 pandemic, the last thing we need to add to our anxiety is a hacker sneaking off with clients’ data – along with those clients’ confidence in their advisors and wealth management firms of choice. Cybersecurity experts have been able to hack into RIA networks using a variety of common workplace mistakes that are even more likely to be committed when we’re working at home. The good news is
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Coronavirus Update
Hello, friends. I hope this coronavirus update from SmartRIA finds you healthy and safe at home. I’m writing to let you know a few things about how SmartRIA is handling coronavirus, how our situation might affect our customers, and in general, to share our thoughts at this difficult moment for everyone. First: as of last week, the SmartRIA team is working from home to do our own small part to help stop the spread of coronavirus. We’re still on the
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How A Culture Of Compliance Can Help Your Firm
As a financial advisor, you know that maintaining federal regulations and client expectations are paramount to the success of your firm. But did you know that creating a culture of compliance is one of the best ways to truly uphold those standards and expectations? It is! Compliance isn’t a one-time, singular occurrence for any firm, it’s a constant series of choices and actions that you and every member of your team are responsible for each day. As a rule, every
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