Blog

As a follow on to my recent post concerning my attendance at the NSCP annual meeting, I want to share with you the speech that was given by Andrew Ceresney, Director, Division of Enforcement of the SEC.  Briefly, his remarks centered around a Chief Compliance Officer’s (CCO) liability at investment advisor firms.  The three takeaways from his remarks were that CCO’s have the Commission’s full support; enforcement actions are brought against business line personnel in appropriate circumstances where the CCO has been deceived or misled or inadequate resources have been provided to help you do your job; and finally, there has been no change in the Commission’s approach to determining whether to charge a CCO.  For Mr. Ceresney’s speech in its entirety here is the link.

Over the upcoming weekend I will be travelling to Washington, DC to attend the Annual Meeting of the National Society of Compliance Professionals (NSCP).  This four day conference is always very well attended by compliance professionals, attorneys, state and federal regulators, vendors and packed with investment adviser sessions on topics like proposed Form ADV changes, proposed new anti-money laundering rules, recent enforcement actions, examination findings for 2015 and proprietaries for 2016, tips for effective compliance programs and many more topics too numerous to mention here.  I look forward to hearing about the latest ‘hot button’ topics and sharing more with you when I return.  More to come soon!

K&L Gates, a widely respected, global law firm, practicing in many areas including Financial Services recently published an interesting Alert outlining the 15 areas that lead to enforcement actions against investment advisers in the first 10 months of 2015.  Many of these 15 areas are what we have heard about in past years.  However, they continue to surface as deficiencies.  As a result, I thought it important to include this Alert here:  SEC Enforcement Actions against Investment Advisers for 2015 for your careful review.  How does your investment advisory firm’s policies and procedures measure against the 15 topics mentioned?  Would you be in violation and subject to a regulatory enforcement action?

Recently, I had the opportunity to “walk to end Alzheimer’s” in the Seacoast, New Hampshire area.  It was a privilege for me to support the Alzheimer’s Association and the good work they do. This walk was also personal for me as I lost my mother to Alzheimer’s seven years ago.  It meant a lot to me to take part in this event and in my own small way contribute to help fight this debilitating disease.  I’m confident this will be an ‘annual walk’ for me.  For more information about the Alzheimer’s Associate visit their website at www.alz.org today!

I attended a very informative workshop recently on Social Media.  The focus was individuals and business owners who currently have a presence on social media but are looking to learn the nuances of various sites in an effort to take their online presence to new levels.  The workshop was hosted by the Somersworth Chamber of Commerce and the speaker was Joanne Randall who is the owner of Sprout for Business.  Sprout is located in Concord, New Hampshire.  Joanne and her partner Neil Burtt, who creates/designs websites work with individuals and businesses across all of the United States.  Personally, I found her knowledge of blogging, FaceBook, Google+, LinkedIn, and Pinterest invaluable.  So much so Joanne has inspired me to start blogging on my website, www.registeredadvisorservices.com.  Stay tuned for more engaging commentary!

I encourage you to contact Sprout for Business today!  Getting the right message out to your clients and prospects is important.