Investment Adviser Regulatory Review 2018

The SEC’s regulatory actions in 2018 involved few surprises but still managed to challenge investment advisers. In reviewing the SEC’s activity over the past 12 months, Jaqueline Hummel at Hardin Compliance Consulting LLC has identified the top regulatory hot buttons to help firms focus their efforts to update their compliance programs for 2019.

Read her full post here.


Looking to update your compliance program in 2019? 

If so, you’ll want to review these eleven key takeaways from Jaqueline Hummel at Hardin Compliance Consulting LLC.

1. Be ready for the SEC’s scrutiny of conflicts of interest.

2. Confirm your compliance program addresses the most frequent advisory fee and expense compliance issues identified in examinations of investment advisers identified in the SEC’s risk alert

3. Review OCIE’s risk alert: most frequent best execution issues cited in adviser exams and confirm your policies, procedures and practices address the deficiencies cited.

4. Review the risk alert: investment adviser compliance issues related to the cash solicitation rule and make sure your firm has a process in place to comply with the requirements of rule 206(4)-3.

5. Address how electronic messaging is being used for business communications and confirm whether your firm is retaining the required records.

6. Be prepared for examiners continued scrutiny of custody issues.

7. Watch your back.

8. Adopt policies and procedures to protect senior and vulnerable investors.

9. Shore up your cybersecurity policies and procedures.

10. Mutual fund and ETF advisers, and their sub-advisers, should review the risk alert: risk-based examination initiatives focused on registered investment companies and prepare to be examined.

11. Advisers to mutual funds and ETFs should be working on their liquidity risk management programs to comply with investment company act rule 22e-4.


Read the full post here.

Broker-Dealer 2018 Regulatory Year in Review

Jaqueline Hummel at Hardin Compliance Consulting LLC has shared Hardin’s list of rules, enforcement actions and regulatory developments for broker-dealers from 2018.

Highlights include:

2018 New & Amended Rules

2018 Notable Regulatory Enforcement Actions

2018 Cryptocurrency Developments

2018 Notable Regulatory Announcements

2019 Upcoming Rule Amendments

Read the full post here.




2019 Regulatory Deadlines for Broker-Dealers and Investment Advisers — Monthly Guides

To help compliance officers plan their regulatory calendars for 2019, we are pleased to share Hardin Compliance Consulting’s lists of regulatory requirements for Broker-Dealers and Investment Advisers.  While not intended to be exhaustive, it does provide a monthly “to do” list to assist you in planning for the year ahead . . .

BD Monthly Guide

IA Monthly Guide

Now if we could just find someone to do this for the other aspects of our lives. . .


OMG! SEC Gives Tips on IM and Texting, More Advisers Caught in 12b-1 Fee Scandal, and Lessons Learned from FINRA Exams

January Regulatory Updates from Jaqueline Hummel at Hardin Compliance Consulting LLC.

Topics include:

Read the full post here