We are reaching out to make you aware of three important compliance items: (1) the SEC Division of Examinations’ June 9, 2026 Risk Alert on economic conflicts of interest; (2) the approaching annual deadline for DOL Prohibited Transaction Exemption 2020-02 retrospective reviews; and (3) the August 31, 2026 deadline for Form N-PX filings. Each of [...]
The U.S. Securities and Exchange Commission (“SEC”) has approved an order adjusting the dollar-amount thresholds used for purposes of the definition of a “qualified client.” These updated thresholds will become effective on June 29, 2026. Under current thresholds, "qualified clients" include clients who satisfy either: The “Assets Under Management Test,” under which the client must, immediately after entering into the investment advisory contract, have at least $1,100,000 in assets under [...]
As the final compliance deadline for the amended Regulation S-P quickly approaches, we’re here to help your firm develop and implement thoughtful and practical policies and procedures. Regulation S-P Amendments What is it? As an update to our October 2025 Compliance Alert, we wanted to remind firms that the SEC adopted amendments to Regulation S-P, [...]
We’re reaching out to help you comply with recent amendments to Regulation S-P and remind you about recently adopted continuing education requirements imposed by many states: As the first compliance deadline for “large entities” under the amended Regulation S-P quickly approaches, we’re here to help your firm develop and implement thoughtful and practical policies and [...]
Each year, investment advisers and their registered personnel are required to renew their registrations for the following year, to ensure that continuous registrations are maintained. This also marks a key time for advisers to review their current registrations and notice-filings, as well as their active rosters of registered personnel, to confirm that all registrations and [...]
Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (the "IA AML Rule") and to revisit the scope [...]
As we typically do in our newsletter, we want to provide you with the following information in an easy and clean format: key dates, relevant proposed and adopted rules, enforcement actions, relevant guidance, and information about our upcoming speaking engagements. Each quarter, we plan to distribute a similar newsletter in this format.While we never want [...]
We are excited and proud to announce the launch of RIA Lawyers—a law firm dedicated to representing investment advisers. We have each spent the better part of the last ten years counseling investment professionals about their legal and compliance needs, including the benefits of going independent. As we enter 2022, we thought it was finally [...]