The amendments to Form ADV became effective on October 1st. Unless you registered with the SEC on or after October 1st or have had a material change requiring an “other-than-annual” amendment since that date, you have not yet seen the following on the amended Form ADV. 1. Separately Managed Accounts Prior to the amendments, investment…

The SEC requires registered investment advisers to maintain a compliance program that implements a written code of ethics and policies and procedures to enforce them. Insider trading is a serious regulatory violation that can be avoided, provided clear and concise policy to control and contain the misuse of non-public material information. The COE is also…

The SEC’s Division of Investment Management recently released a Guidance Update which provides important guidance for investment advisors to mutual funds on managing the acceptance of gifts and entertainment from those doing or hoping to do business with the investment adviser. The guidance discusses the inherent conflicts of interest presented by the receipt of gifts…

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