Last week I took time to attend the N40 Digital Asset Summit which brought together industry leaders, innovators, and family offices to discuss the future of blockchain, digital assets, Web3, crypto and the role for AI in the space. The event was robust with fabulous panels and a wealth of information and insight.  As US

Happy New Year to all and Welcome to Thompson Hine’s newest blog offered as a service to those in the investment management and broker-dealer communities.

What a better way to begin this blog then discussing the problems that arise for RIAs and BDs at this time of year. The first and most pressing for RIAs

complianceThe exam is finally over! If your advisory firm has been undergoing an SEC examination, you’ve probably been waiting a long time to utter those words. Well, time to get back to business, right? Not so fast. As our series on SEC examinations has detailed, this is a long process. And if your firm received

An onsite examination from the SEC can often feel like a surprise visit from your in-laws.  You wish you had more time to clean up before they arrived, you know they’re judging you the whole time they’re there, and you can’t wait for the moment you get to say goodbye.

And, after what seems like

You open your inbox, ready to start your day, and what’s the first thing that greets you? A notice that you’re being examined from the SEC’s Division of Examinations (EXAMS), along with an initial request list for information. Time to panic? Of course not. Being examined by the SEC, and other regulatory authorities, is an

So you’ve built your robo-adviser, registered it, hired and licensed personnel, implemented a compliance program, conducted a successful marketing campaign, and (finally) gotten to do what you’ve really wanted to do the whole time – advise clients and manage portfolios.  Startup woes seem a thing of the past, and your operation is running smoothly.

Then,

target

For nearly a decade now, regulators have placed the Chief Compliance Officer (“CCO”) squarely within the sights of enforcement, on the logic that holding CCO’s individually liable for violations would prompt robust compliance programs, and deter lackluster supervision. The reasonableness of such assumptions is a topic for a different post.  However, despite these drastically raised the stakes