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Evaluating and Integrating Regulatory Technology in an Advisory Firm Compliance Program
Regulatory technology (“RegTech”) continues to evolve, and many advisory firms are reassessing how technology can support oversight, documentation, and risk management to help control compliance-related costs without requiring a proportional increase in internal staffing or manual effort. For some firms, manual processes remain workable. For others, increasing regulatory expectations, staffing constraints, and operational complexity are prompting a closer look at whether tech

Coulter Strategic Services
Jan 610 min read


The Proactive CCO: Building Systems to Track and Implement Regulatory Change
Effective compliance programs stay ahead of regulatory developments rather than reacting to them at the last minute. Whether you are new to the team, experienced in the role, or somewhere in between, being proactive is a skill that helps protect clients, strengthen operations, and reduce exam-related surprises. Regulatory expectations evolve quickly, and firms that monitor updates in a structured way are far better positioned to adapt without disruption. Establish a Consisten

Coulter Strategic Services
Dec 8, 20254 min read


Stepping Into the Role: Building or Rebuilding a Compliance Program as a New CCO
Stepping into the Chief Compliance Officer role for a registered investment adviser can feel overwhelming, whether you are a dedicated compliance professional or an owner or principal who has taken on the CCO title. This is true even if day-to-day tasks are delegated to support staff or an outside compliance consultant, because responsibility for the program ultimately remains with the firm and its CCO. The key is to pause, assess, and rebuild on a sound foundation before mak

Coulter Strategic Services
Dec 2, 20256 min read


Unauthorized Marketing Claims, Weak Records, and a Missing Annual Review: A Case Study in Fundamental Compliance Failures
In its September 2025 order, the Securities and Exchange Commission found that a registered investment adviser violated the Marketing Rule , recordkeeping requirements, and the annual compliance review obligation under Rule 206(4)-7. The adviser made a prominent claim on its website that it “refuse[d] all conflicts of interest,” while its own compliance manual acknowledged that “conflicts of interest are inherent in the role as an investment adviser.” The SEC concluded that t

Coulter Strategic Services
Nov 24, 20253 min read


The Anthropic AI Incident and What Firms Must Address Immediately
Artificial intelligence is now a standard part of the cyber landscape, and the recent disclosures involving Anthropic and its Claude model have become a clear warning for financial advisory firms. The incident did not involve advisory firms directly, but it revealed a level of data exposure that all firms need to understand and address. What Happened Anthropic reported that a state-sponsored group in China used the Claude and Claude Code models to support targeted cyberattack

Coulter Strategic Services
Nov 19, 20255 min read


Pre-Clearance Under Pressure: Document Integrity and Personal Accountability
The SEC’s July 2025 administrative action against a former Chief Compliance Officer underscores a simple but critical truth: integrity of the compliance record is non-negotiable. According to the Commission’s findings, the CCO “altered, fabricated, and caused others to fabricate” pre-clearance records to make it appear that certain trades had been properly reviewed and approved before execution when, in fact, they had not. These altered documents were then provided to SEC exa

Coulter Strategic Services
Nov 17, 20253 min read


Unauthorized Fees and Misused Client Credentials: A Case Study in Basic Controls
The SEC’s 2025 enforcement action against a registered investment adviser highlights how routine administrative shortcuts, rather than intentional theft, can still lead to severe fiduciary violations. The Commission alleged that advisory personnel charged millions of dollars in unauthorized fees by directly accessing client brokerage accounts using client credentials and rerouting multi-factor authentication (“MFA”) codes to firm devices. According to the complaint filed in f

Coulter Strategic Services
Nov 10, 20254 min read
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