Earlier this month, FINRA agreed to a Letter of Acceptance, Waiver, and Consent (AWC) imposing a $10 million fine and finding that, from 2018 through at least February 2024, the brokerage firm violated FINRA Rule 2341(l)(5), which generally prohibits broker-dealers from paying or accepting non-cash compensation tied to sales, as well as recordkeeping and supervisory
Monday, November 10
11:30 a.m. – 3:30 p.m. ET
We are pleased to invite you to the RIA Merger Conference, an exclusive in-person event in New York City (virtual option also available) designed specifically for registered investment advisers. This half-day panel program offers a unique opportunity to engage with peers and industry and thought leaders while exploring
The U.S. Securities and Exchange Commission (SEC) has announced the appointment of Brian T. Daly as the new Director of the Division of Investment Management, effective July 8, 2025. Daly, a highly regarded figure in the investment management industry, brings decades of experience advising fund managers and sponsors on regulatory compliance and legal matters.
Daly’s
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
The 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
Our recent posts have walked you through the SEC’s new marketing rule and discussed valuation and fee assessment. Now, with the ADV season, hopefully, in your rear-view mirror, we turn your attention to planning for the remainder of the year. Determining the most efficient use of a compliance department’s time and resources is essential. Fortunately,
Over the last three posts to the blog (overview, performance, promoters), we’ve interrupted our previous schedule to provide insight into the U.S. Securities and Exchange Commission’s (“SEC”) recently adopted changes to the rules governing investment adviser marketing and advertising. In today’s post, we resume our previous topic thread focusing on the
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
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