Lessons Learned 

• The War on “May” Continues: SEC Charges Advisor and Dual-Hatted CCO Over Inadequate Disclosures About Fee Mark-Ups
• Form CRS Violations Continue. The SEC recently fined two more advisors for Form CRS violations similar to 27 enforcement actions brought against broker-dealers and advisors in July.

Worth Reading, Watching, and Hearing

• SEC Pulls Years of No Action Letters Replaced by Marketing Rule.
• Cybersecurity: Meeting the Emerging Challenge.
• How to Nail Your Executive Presentation – 5 Best Practices to Gain Leadership Support 
• Ted Lasso Is Reinventing Leadership and Proving That Nice Leaders Can (and Should) Finish First
• Finding Your Career Path in Compliance

December Regulatory Updates from Cari Hopsfenperger at Foreside.

Topics include:

• SEC Withdraws Several No-Action Letters related to Marketing Rule.
• 2021 Compliance Outreach Program Regional Seminars for Investment Advisor and Investment Company Senior Officers. 
• Risk Alert – Observations from Examinations in the Registered Investment Company Initiatives
• The Renewal Process Continues 
• FINRA Annual Renewal Overview
• IARD Renewal Program Overview

Read more here.

November Regulatory Updates from Cari Hopsfenperger at Foreside.

Topics include:

• A reminder about the importance of cybersecurity (hygiene, best practices, and vigilance) and to visit CISA (https://www.cisa.gov/cybersecurity-awareness-month) for valuable (and free) resources to help you reduce your exposure to these threats
• NASAA Reports Top Enforcement Trends for 2020:  Precious Metals Swindles, Online Investment Scams, Dodgy Private Offerings, and Self-Directed IRA Rip-Offs
• SEC Regional CCO Virtual Outreach
• DOL Agrees to Back Off on Enforcement of Compliance with ERISA Fiduciary Obligations for Rollover Advice until January 31, 2022
• The 2022 Renewal Program is Underway.  November marks the beginning of the annual renewal cycle for broker-dealers, registered representatives, investment advisors, and investment advisor representatives (IARs)
  FINRA Annual Renewal Overview
  IARD Renewal Program Overview
• FINRA “Encourages” Members to Consider Updating Their AML Programs
• FINRA, NASAA, and SEC Urge Investors to Establish a Trusted Contact to Increase Investor Protection
• Out of Sight, Out of Mind – Advisor Continued to Charge Clients Fees for No Services After IARs Departed
• “Probability of Human Error is Considerably Higher than That of Machine Error” ~Kenneth Appel
• A Precarious House of Cards and a Royal Flush of Violations

Read more here.