Posts By: Keith Marks

SEC Proposes Amendments to Advertising Rules

In a proposal that would mark the first changes since 1961, the SEC has introduced amendments to modify the “Advertisements by Investment Advisers” Rule 206(4)-1 of the Investment Advisers Act. Changes to the rule would allow for testimonials and social media practices beyond that currently allowed, and performance marketing subject to new requirements. Some parts … Continued

Technology Advances Here and On the Way for Form CRS

CSS featured a strong presence at the recent 2019 BAM + Loring Ward Advisor National Conference in St. Louis, Mo. The conference, titled “In Our Element,” explored the chemistry of investment advisors’ relationships with their clients and the keys to successfully building those relationships. Within that context, CSS’s compliance presentation outlining the purpose and implementation … Continued

SEC Adopts Regulation Best Interest, Form CRS; Also Issues Interpretive Releases on IA Fiduciary Duty and Solely Incidental Exception

By a 3-1 vote, on June 5, 2019, the SEC acted to provide a new regulatory framework to help retail, or main street, investors understand the distinctions between broker-dealers and investment advisers, particularly the standards of conduct owed by each. Opening remarks by SEC Chair Jay Clayton noted that as markets have developed over the … Continued

Regulation Best Interest, Cybersecurity Top Concerns at IAA 2019 Compliance Conference

The Investment Adviser Association (IAA) represents the interests of investment advisers in Washington D.C., and the IAA Investment Adviser Compliance Conference 2019 was a forum for the discussion of future potential rulemaking. Cybersecurity and Fiduciary Rule considerations were headline topics, with custody and marketing right behind. The following is a summary of key issues discussed … Continued

Pennsylvania Sounds Warning Bell Over Client Credentials and Custody

The Pennsylvania Department of Banking and Securities (PDOBS) has indicated in recent guidance two concerns related to investment advisers using client credentials to access a custodial account(s). In the letter dated September 25, 2018, PDOBS indicates that the use of client credentials may create custody and is considered to be a dishonest and unethical practice. … Continued


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CSS frequently publishes blog posts which are written by our team from their observations in the field, at conferences and through experiences with compliance professionals. These posts are designed to further knowledge and share industry best practices. Topics run the gamut, including Form ADV, cybersecurity, MiFID II, position limit monitoring, technology challenges and more. Complete and submit the brief form below to receive notifications when we publish new content.

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