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

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

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

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

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

Growth through acquisition can bring exciting opportunities new clients, expanded resources, and greater scale—but it also introduces one of the most complex challenges a firm can face: merging two compliance programs into one. Whether your firm is acquiring another practice or integrating into a new organization, compliance should be part of the process from the very beginning, not after the documents are signed. Engage Compliance Early in the Process Compliance should play

For registered investment advisers, the written Policies and Procedures Manual and Code of Ethics are required components of the compliance program under the Investment Advisers Act of 1940. These documents form the operational foundation of an adviser’s compliance framework and are among the first items regulators review during an examination. A well-crafted manual should accurately reflect how the firm operates, supervises its personnel, and manages risk. By contrast, a gen

Introduction For many advisory firms, the annual compliance review is a recurring line item on the calendar, one that too often becomes a documentation exercise rather than a diagnostic one. Under Rule 206(4)-7, however, the annual review is a cornerstone of every adviser’s compliance program. Done well, it is not only a regulatory requirement but also an operational stress test that can highlight both compliance gaps and business inefficiencies. While the rule itself is conc

A recorded discussion with Coulter Strategic Services and MTradeCraft on the responsible use of artificial intelligence in advisory firms. This session covers privacy considerations, compliance steps under SEC requirements, and practical ways to use AI tools securely and effectively. Learn how to protect client data, improve output quality, and align AI use with your firm’s fiduciary and regulatory obligations. All information provided is for educational purposes and shall no

April 10, 2025 With Paul Atkins confirmed on April 9, 2025, as Chair of the U.S. Securities and Exchange Commission , a shift in tone is...

Recent regulatory scrutiny has highlighted how the misuse of social media can blur the lines between personal market opinions and...

Enhance Your Understanding of Form ADV – 2025 Course Now Available! Whether you're a seasoned compliance professional, an investment...

The financial exploitation of seniors and vulnerable adults is an increasing concern in today's society. As the population ages, the...

Introduction The financial exploitation of seniors and vulnerable adults is an increasing concern in today's society. As the population...

Proposed Rule: Enhanced Safeguarding Rule for Registered Investment Advisers (Proposed Date: February 15, 2023) The proposed Enhanced...

Advisory firms are subject to various regulations aimed at safeguarding client data, including the Red Flags Rule under the Fair Credit...

As the regulatory landscape for Registered Investment Advisers (Firms ) continues to evolve, staying ahead of proposed rules is crucial...

Introduction Hypothetical performance is a key component of the SEC’s Marketing Rule, which imposes specific criteria that firms must...

The recent global outage caused by a faulty CrowdStrike update, which affected Microsoft Windows systems worldwide, serves as a critical...

We are pleased to announce the release of an insightful pre-recorded presentation titled "Balancing Innovation with Regulatory...