Tag Archives: Advisers

SEC Rules and Guidance for Investment Advisers Standard of Conduct

Posted by Jessica Forbes and Joanna Rosenberg, Fried, Frank, Harris, Shriver & Jacobson LLP, on Saturday, May 12, 2018 Editor's Note: Jessica Forbes is a partner and Joanna D. Rosenberg is an associate at Fried, Frank, Harris, Shriver & Jacobson LLP. This post … Continue reading

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Investment Advisers Cautioned not to Use Client Usernames and Passwords to Access Accounts

Investment advisers’ use of clients’ usernames and passwords to access their clients’ accounts to observe the accounts’ performance has come under scrutiny in recent years.  In February 2017, the SEC Office of Compliance Inspections and Examinations (“OCIE”) disclosed in a … Continue reading

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The SEC’s Scare Tactics May Work on Advisers

In rapid succession, the SEC has issued warnings and announced sanctions against registered investment advisers for fee and expense practices, false statements regarding assets under management, and misleading performance data.  No one should be surprised that the SEC is actively … Continue reading

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SEC Launches Self-Reporting Initiative for Investment Advisers

In line with Chairman Jay Clayton’s oft-stated priority of protecting the long-term interests of Main Street investors, on Feb. 12, 2018, the Securities and Exchange Commission’s Division of Enforcement announced the launch of a new self-reporting initiative for investment advisers. … Continue reading

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Form ADV Amendments Vexing Some Advisers

The amendments to Form ADV, Part 1 that became effective October 1, 2017 are presenting some registered investment advisers with unforeseen problems as we move into “annual amendment season” in 2018.  As we previously highlighted among those changes to Form … Continue reading

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