Now that the holidays are behind us and we look forward to a promising new year, I find myself marveling at the year we had and proud of the results we achieved. We were busy on-boarding many new clients and continuing to manage and update the compliance programs for our existing clients. Meanwhile, the OCIE…

In September 2017, the OCIE issued a Risk Alert notifying advisors of the most common deficiencies related to the Advertising Rule. Interestingly, all the deficiencies identified involved misleading performance advertising. The takeaways from the Risk Alert are detailed below. Misleading Performance Results. The Staff observed advisers that presented performance results without deducting advisory fees. The…

On August 25, 2016, the Securities and Exchange Commission (“SEC”) adopted amendments to the Investment Advisers Act of 1940 (the “Advisers Act”) and Form ADV to enhance and improve the reporting requirements for registered investment advisers (“RIAs”). The Amendments become effective on October 1, 2017. According to the Adopting Release, the purpose of the Amendments is…

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