Compliance and Consulting

The Impact of the SEC’s Custody Clarification Guidance

The Division of Investment Management (DIM) of the U.S. Securities and Exchange Commission (SEC) recently issued three different clarifications that have an impact on whether a registered investment adviser (RIA) has custody of client assets under Rule 206(4)-2 of the Investment Advisers Act of 1940, commonly known…more

Managing Tech in the Broker-Dealer Industry

Customer service is key in driving the growth of business. In the highly-regulated broker-dealer industry, a focus on better customer service is often the distinction between competing firms.

The ongoing Fintech revolution in the financial services industry has opened up innovative options for representatives to be more accessible…more

Proposed Update to Fair Value Disclosure Requirements

In December 2015, the Financial Accounting Standards Board (FASB) issued a proposed Accounting Standards Update, Fair Value Measurement (Topic 820): Disclosure Framework—Changes to the Disclosure Requirements for Fair Value Measurement. The proposal is an element of the FASB’s broader disclosure framework project. This project is expected to promote…more

Proposed Amendments to Books and Records Rule 204-2

The SEC recently made available the comments received on IA-4091, Amendments to Form ADV and Investment Advisers Act Rules. First, let’s revisit some specifics of the amendments, originally introduced on May 20, 2015. The first of the amendments is to Form ADV Part 1A, specifically as it relates…more

A Partnership in Operational Due Diligence

The landscape of the financial markets is full of constantly evolving regulation, complex financial instruments, customized investment structures, and increased scrutiny from investors. Now may be the time to evaluate your operational due diligence program.

What is Due Diligence?

Generally, due diligence refers to the care a reasonable person would…more

An Update on NAV Per Share – ASU 2015-07

On Friday, May 1, 2015, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) 2015-07, Fair Value Measurement (Topic 820): Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent).

The amendments apply to reporting entities that elect to measure the…more

Update on PCAOB Inspection of Broker-Dealers

In August 2011, the interim inspection program of auditors was implemented due to new authority given to the Public Company Accounting Oversight Board (PCAOB) over auditors of SEC-registered broker-dealers by the Dodd Frank Wall Street Reform and Consumer Protection Act.

The PCAOB issued its first two progress reports…more

Proposed Accounting Standards Update on NAV Per Share

The Financial Accounting Standards Board (FASB) has issued a proposed Accounting Standards Update (820), “Fair Value Measurement (Topic 820): Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent).” As a reminder, comments on the proposed ASU are due January 15, 2015.

What Led…more

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