Word-of-mouth is still one of the best ways to attract business. Investors, whether new or seasoned, consistently look to the experiences of previous customers or talk to someone they trust before they hire a financial adviser. As a result, posting great reviews and compensating others to make recommendations continues to be a key part of
Today we continue our discussion of the SEC’s recent changes to the Advertising Rule. In our last post, Josh covered the general definitional changes and prohibitions. In this entry, we will highlight the new Advertising Rule’s impact on performance advertising.
As we have discussed, the amended rule consolidates and supersedes former rules 206(4)-1 and
We interrupt our regularly scheduled programming to bring you this special update. Well, technically it’s the U.S. Securities and Exchange Commission’s (“SEC”) update and it pertains to the regulation of investment adviser advertising. On December 22, 2020, the SEC amended the current regulatory framework governing investment adviser advertising. In making these changes, the SEC incorporated
If there was ever a reason to follow Josh’s advice to involve compliance early in building out the functionality of your robo-adviser, the recordkeeping requirements of the Advisers Act are it. As Josh mentioned in his post, Advisers Act Rule 204-2 imposes extensive recordkeeping requirements that you’ll want to be familiar with from the
By Marc B. Minor
Investment advisers, rightly, focus much of their attention on satisfying their fiduciary duty through careful investment recommendations. However, advisers’ duties also include ensuring that client cash and securities are transferred for investment, and held, safely by the custodian of those assets.
For robo-advisers, client onboarding, facilitating the transfer of funds and
Thus far, our review of the necessary components of your compliance program has focused on discrete areas. This post focuses on another equally important aspect of your compliance program that touches all of those other areas; ensuring the accuracy of your disclosures. After all, what’s the point of putting in all of the hours to
When it comes to trading in your firm’s own investment accounts (proprietary trading), it’s never cherry-picking season. Instead, when allocating investment opportunities, you should follow the golden rule – treat your clients like you want to be treated.
What does this mean? As an investment adviser, your fiduciary duty requires you to allocate securities and
Our blog recently discussed how soft dollar arrangements can impact the bottom line for both advisers and investors, and therefore require adequate disclosure. Other compliance requirements involve non-client facing operations, but are equally important to monitoring and protecting against conflicts of interest. The Personal Trading Policy is one such requirement.
The Investment Advisers Act and
In our last post, Craig began our discussion of trading practices by examining an adviser’s duty to obtain best execution. This post continues our trading practice discussion with a focus on soft dollar arrangements.
Soft dollar arrangements generally arise when an adviser receives research or brokerage products or services from a broker-dealer in exchange
So, let’s say your robo-adviser firm has created a brand new strategy that you think would be attractive to investors. You’ve registered your firm, licensed your personnel, built and tested the algorithm, and now you’re ready to bring your strategy to market. Now, all you need to do is find a broker who