8/30/2010
You're probably debating the idea now: Should we produce the new narrative brochure in-house or hire an outsider? If you want to outsource the task, check out what some consultants say.If the RIA has "done things properly, we should have a pretty good idea of how the company operates" by reading its ...
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8/30/2010
Satisfy the SEC's vision of your job and you're a long way toward success. So let's examine another CCO duty on the list of 24 enunciated by OCIE Associate Director Gene Gohlke (IA Watch, Jan. 18, 2010):Becomes involved in analyzing and resolving significant compliance issues that arise.Achieving th ...
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8/30/2010
This story begins a series in which we'll pass on expert guidance to help you comply with the SEC's new requirement for a narrative brochure (IA Watch, Aug. 2, 2010), including a look at the toughest challenges along with suggested solutions.One challenge will be satisfying the intent: providing mor ...
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8/23/2010
Our story last week on best practices when dealing with elderly investors (IA Watch, Aug. 16, 2010) just so happened to coincide with the SEC's new guidance on Aug. 13. OCIE, along with NASAA and FINRA, released ways your peers respond to elderly clients in an addendum to their 2008 guidance.The new ...
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8/23/2010
People take in information differently in today's culture so it may be best to communicate your firm's compliance policies and procedures through the use of forms, tables and checklists."I'm becoming more and more a fan of matrix-driven policies and procedures rather than" narrative descriptions, sa ...
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08/17/2010
Click here to open a Word file that Michelle Heyne, CCO at McAdams Wright Ragen in Seattle, shares with you. We thank Michelle for her contribution.
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08/17/2010
This is a portion of a policy and procedure related to supervision at an RIA. This comes from Nancy Lininger with The Consortium in Camarillo, Calif.
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8/16/2010
You hear more reports of firms turning to e-mail encryption, perhaps spurred on by that new Massachusetts regulation or simply as a means of offering clients greater protections against identify theft.Turn that concept around now and consider when clients send your firm encrypted e-mails. One of you ...
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8/16/2010
Say one client needs to sell some shares and your portfolio manager crosses the trade with another client. How can you be sure that the PM has followed your firm's procedures and slipped the latter client a security that's right for his portfolio?Answer: Conduct a forensic test.That's among the reco ...
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8/16/2010
This real-life scenario captures the challenges faced by money managers today, especially when overseeing several funds and owing a fiduciary duty to each. To simplify the description, say the manager has fund A and fund B and seeks to move securities from one to the other.Complicating this arrangem ...
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