Most RIAs that receive deficiency letters after an SEC examination didn’t know they had a problem. That is not a defense. It is the pattern. The findings that show up most consistently […]
The promotion makes sense on paper. The ops manager who built the firm’s compliance program from scratch, who knows where every policy lives and why every procedure exists, and who has been […]
Here’s the assumption worth examining before the conversation with a small business client goes too far: a Pooled Employer Plan is not a retirement plan product. It is a liability structure. And […]
Most of the AI conversation in wealth management compliance has been happening at the wrong altitude. Vendors are demonstrating what AI can theoretically do. Regulators are warning about what AI might do […]
The examination notice arrives and the first call the CCO makes is usually to their compliance consultant. The second call, more often than not, is to whoever manages the shared drive. What […]
Form PF has been a compliance burden for private fund advisers since its introduction following the Dodd-Frank Act, and that burden grew significantly with the amendments adopted in 2023 and 2024 under […]
The AI conversation in wealth management has a familiar shape right now. A vendor demonstrates something impressive, the audience asks whether it could replace a compliance function, and the answer is either […]
The compliance mistakes new RIAs make aren’t usually dramatic. Nobody misses a filing deadline on purpose or decides to skip the written supervisory procedures altogether. The failures are quieter than that. Assumptions […]
When the SEC examination notice arrives, most RIAs do the same thing: they stop everything else and start preparing. Two weeks of pulling files, reconstructing approval trails, chasing employees for documentation that […]