Investment advisers and broker dealers and other persons in relationships of trust that must keep confidential a client’s contact information and wishes must be able to go outside of that circle of trust from time to time. However, laws such as Regulation S-P prohibit them from doing so. That is why many investment adviser inContinue reading “Trusted Contact Persons and Sample Form”
Back in December 2014, the Securities and Exchange Commission (“SEC”) approved a Financial Industry Regulatory Authority (“FINRA”) rule governing transaction-based payments to unregistered persons. The FINRA rule—Rule 2040—became effective on August 24, 2015. I understand that FINRA is currently considering providing members and the industry with written guidance so that their registered representatives can receiveContinue reading “Payments of Transaction-Based Compensation by FINRA Members – An Update for Selling Groups and Individual Service Corporations and New Interpretive Guidance on the Horizon?”
Here is a discussion on completing Form ADV and submitting annual updating amendments. We discuss: the timeline for submitting annual updating amendments, how to collect data, seeking input from operations and business units, taking positions on ambiguous questions, identifying conflicts of interest and adequately disclosing them, and recent trends in Form ADV Part 2A disclosure.