Tag: Korrine Kohm

Effective Compliance Policies & Procedures and Annual Reviews: Meeting the Reasonably Designed Standards

Sometimes it seems that enough is never really enough. While compliance officers have grown intimately familiar with SEC Rule 206(4)-7 over the past 15 years since the Rule became effective, deficiencies in connection with the Compliance Program Rule continue to rank among the most frequently cited issues identified in OCIE examinations of investment advisers. It … Continued

From Wall Street to Main Street: Update on Standard of Conduct for Investment Advisers

Retail investors are confused! They fundamentally cannot differentiate between a broker-dealer and an investment adviser. And that has the SEC concerned. So when the DOL Fiduciary Rule was overturned earlier this year, the SEC stepped into the debate with its April proposal. And that was a key topic of discussion at the recent CSS/Ascendant fall … Continued


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