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Three Investment Advisers Sanctioned for Repeatedly Ignoring Problems with their Compliance Programs

Three Investment Advisers Sanctioned for Repeatedly Ignoring Problems with their Compliance Programs

Mitch Avnet
No Comments
October 28, 2013

Three Investment Advisers Sanctioned for Repeatedly Ignoring Problems with their Compliance Programs. Read the press release here: http://ow.ly/qf0PP The recent action taken by the SEC against three Investment Advisers should serve as a “wake up call” for the IA sector. IAs must ensure they have regular and rigorous compliance programs in place to keep pace with industry requirements and expectations. IAs should utilize the recent sanctions as a “road map” / “checklist” for their own internal controls.

“The Compliance Program Initiative is designed to address repeated compliance failures that may lead to bigger problems,” said Andrew J. Ceresney, co-director of the SEC’s Division of Enforcement. “That risk materialized with these firms, whose compliance programs were not adequate to prevent misleading statements in marketing materials or inadvertent overbilling of clients. Firms must not only have policies and procedures in place, but also need to properly implement those policies and procedures.” The firms charged today – Modern Portfolio Management Inc., Equitas Capital Advisers LLC, and Equitas Partners LLC – have agreed to settlements in which they will pay financial penalties and hire compliance consultants.

As part of your ongoing IA Compliance responsibilities, CRC can assist with the following discrete activities:

  • Mock SEC Exams
  • Gap Analysis
  • Advertising and Marketing Reviews
  • Access Person / Personal Account Trading Reviews
  • Form ADV Part 1, 2A and 2B
  • Annual Compliance Reviews –Rule 206(4)-7 of the Investment Advisers Act
  • Code of Ethics
  • Drafting / Revision of Policies and Procedures

For further assistance or an introductory conversation, please contact Mitch at Compliance Risk Concepts.

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