Five Things Regulators Want to Know about the Way You Do Business
|
|
- Martha Webb
- 5 years ago
- Views:
Transcription
1 PRACTICE MANAGEMENT Five Things Regulators Want to Know about the Way You Do Business April 9, Views In letters detailing the regulatory issues of greatest concern, SEC and FINRA fail to distinguish between RIAs, broker-dealers and other regulated entities. This Practice Management article is intended for financial advisors only (registered representatives of broker/dealers or associated persons of Registered Investment Advisors). When it comes to compliance issues, the line between RIAs and broker/dealers seems to be getting f uzzier. At the beginning of the year, when the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) published letters detailing the issues of greatest concern f or examiners, compliance experts noted a surprising similarity. And in laying out its examination priorities, the SEC s Of f ice of Compliance Inspections and Examinations broke with past practice and f ailed to distinguish between areas of concern specif ic to registered investment advisors (RIAs), broker/dealers, and other regulated entities. The f act that they kind of jumbled everyone together in the same sandbox, at least excluding exchanges, was interesting in that they re treating broker/dealers and advisors all of a piece, says Glen Barrentine, a corporate partner at the law f irm Winston & Strawn, where he chairs the broker/dealer regulatory practice. It s also very closely coordinated with FINRA s priorities. Compliance experts are quick to note that the SEC s annual examination letter is by no means comprehensive, and they stress that when examiners visit a practice, their review will not be limited. Yet the priorities letter is the commission s way of putting registrants on notice that they ignore the issues identif ied at their own peril. RIAs should look through this entire letter and really use this as a way of testing their compliance program, says Brian Hamburger, CEO of MarketCounsel, a compliance consulting f irm. What issues are the regulators watching now? A close reading of the examination guidance f rom both the SEC and FINRA suggests that these five issues are now the top areas of concern. 1) Retirement Rollovers The SEC begins its exam priorities with a warning about protecting retail investors and investors saving f or retirement, and highlights as areas of concern the products advisors recommend and the sales practices they engage in when pitching retiring employees on rolling over their 401(k) plans. FINRA similarly warns about rollovers and other wealth events involving the transf er of large sums of money. In the rollover space, the SEC is concerned that advisors and brokers are engaging in improper or misleading practices to steer clients out of their employer-sponsored plans and into other 1
2 investments that could carry higher f ees and greater risks. The potential f or a conf lict in rolling over an employer plan arises when the advisors will pocket a commission or increase their management f ees by goosing their assets under management (AUM). Some people, their first thought is, Oh, I ve got a chance to move this over. I ve got a chance to gain some AUM here. That can t be the f irst thought, says Jason Wainscott, chief compliance of f icer at OJM Group, an RIA headquartered in Cincinnati. There s really no reason to do it just to get it into your firm if it s not in your clients best interest. I think the SEC is picking up on that. Part of being a f iduciary is making sure that your client understands what they re getting into because if you don t, it s going to come back to haunt you, Wainscott adds. Both the SEC and FINRA have noted investors increasing reliance on IRAs in planning f or retirement. The commission also points out that advisors and brokers are presenting retail clients with a growing menu of complex investment products and advice, raising questions about the suitability of their recommendations. It s not just broker/dealers it s registered investment advisors who have to be concerned about suitability as well, and these products are getting more and more complex, says Jay Baris, chair of the investment management practice at the law f irm Morrison & Foerster. I would tell [advisors]: First of all, make sure your disclosure to customers is state of the art and not misleading, Baris continues. Number two, I would remind them that they re f iduciaries, and if you re a registered investment advisor you need to put your clients interests f irst. Some advisors, however, argue that the regulatory concerns may be misplaced. Craig Rollins, a partner at LJCooper Wealth Advisors in Orem, Utah, said his team helps clients roll over their 401(k) plans all the time but that the conversation always starts with a review of the f eatures of the old plan and an examination of what s in the best interest of the client. Too of ten, Rollins argues, employers impose restrictions on 401(k)s f or f ormer employees, cutting of f active management and making those plans a less attractive retirement vehicle than many other options. He worries that the heightened scrutiny f rom regulators could compel advisors to shy away f rom rolling over clients 401(k)s, even when that would be the best move f or the client. Rollovers for RIAs? Frankly, I m a little bit baffled at why they re tackling this at all, Rollins says. The problem in our industry has always been there are a f ew bad actors that create situations while the rest of us in the industry who are trying to do it the right way are penalized. Washington watchers note that there hasn t been much enf orcement activity against advisors working in the retirement space, but anticipate that that could soon change. I think that s coming, says Duane Thompson, senior policy analyst at f i360, a f iduciary training firm. I think that is one of the areas that the SEC and FINRA are going to continue to look at, and I would guess that this year or next you are going to start seeing headlines. 2) Cybersecurity Amid a steady stream of headlines announcing the latest hack into one corporate network or another, it s no surprise that f inancial regulators are growing more concerned about the industry s cybersecurity def enses. The SEC gave the issue only a passing reference in last year s guidance, but the agency convened a cybersecurity roundtable soon af ter and launched a sweep of exams f ocusing on the ways advisors and brokers were saf eguarding systems and data. Those exams will continue during 2015, and expand to include transf er agents, the commission said. 2
3 The SEC identif ies cybersecurity as a market-wide risk in its 2015 exam priorities and Hamburger cautions that advisors must treat the issue as much more than a check-box compliance exercise. This really should be important f or advisors, not because of the regulatory issue. It s almost embarrassing when the SEC comes in and f inds cybersecurity violations, Hamburger says. Advisors really should be paying attention because it s good business, he adds. This is loss of confidence from your clients. This is a far greater currency that you re trading with. Hamburger anticipates that the SEC could put forward a proposed rule or at least a concept release as it mulls how to strengthen the industry s cybersecurity standards although regulating or legislating in an area as f ast-moving and technically complex as cybersecurity is inherently challenging. And don t expect that small RIA shops will get a pass, Hamburger says: If they re a big enough firm to collect sensitive data, they re a big enough firm to protect it. 3) Fee Selection Last year, the SEC issued a warning to advisors who were dually registered as RIAs and brokers, cautioning the industry to take care when placing clients in accounts where f ees are assessed on commissions or as a percentage of AUM. Among the chief concerns was the fear that dual registrants would place an account that they knew would be traded lightly if at all in the advisory side of the practice simply to garner the management f ee. This reverse churning issue appears again in this year s letter, though regulators also warn of the potential harms that can arise with all manner of other f ee structures, including wrap f ees, hourly fees and performance-based fees. Where an adviser of f ers a variety of f ee arrangements, we will f ocus on recommendations of account types and whether they are in the best interest of the client at the inception of the arrangement and thereaf ter, including f ees charged, services provided and disclosures made about such relationships, OCIE says in its letter. That issue is already very much on the radar at large independent broker/dealers like Commonwealth, where Chief Compliance Of f icer Paul Tolley says his team reviews an automated f eed that f lags inactive accounts. With that inf ormation in hand, Tolley s surveillance team might approach an advisor to inquire about the basis f or the account placement and conf irm that the client is, in f act, receiving additional planning or advice to warrant the management f ee. This is a subject that we have looked at for years, Tolley says. We have long since had a report that identif ies... households in managed accounts where there is a period of inactivity. It s not to say [an advisor should] trade for the sake of trading. It s to say, you ve got to be managing those clients, those accounts, those assets on an ongoing basis. With f ees, as with complex products, compliance experts stress the importance of providing clients with f ull disclosures, and then generating a thorough record to document why the account type or investment vehicle is in the client s best interest. What they re saying is, you have to look at all the various fees you offer, and how you disclose those to your clients. Are there fees that are obviously better or worse for your clients within that structure? Barrentine says. You have a duty to make sure that either you put people in the fee structure that is in their best interest, or you make sure that if they re making those decisions, they understand what the f ee structures are. Wainscott says he presents advisors at his f irm with a simple test when evaluating f ee arrangements. 3
4 If you can t explain the fee structure to me in a way that I understand it right away, then I m generally going to advise against getting anyone into it, he says. That s part of being a f iduciary, is making sure that your client is comf ortable and understands what they re getting into because if you don t, it s going to come back to haunt you. 4) Big Branch Offices In a further hint at greater regulatory overlap for advisory and broker/dealer firms, the SEC is calling attention to issues arising with branch of f ices, raising the concern that registered representatives and advisor representatives could be out of step with the standards of conduct at the f irm s headquarters. You see a convergence of the regulatory concerns here, Baris says. What they re looking f or here is: Are there cowboys... in the branch office? That issue is a concern at LJCooper, which has branches in Colorado and Florida. You always run the risk when you ve got people operating out of a branch, which is why a lot of our stuff is centralized, says Rollins, who has helped put in place a consolidated operating structure. Branch personnel have limited autonomy and are subject to periodic reviews, he says, and Rollins and other principals in the f irm will occasionally drop in f or a site visit. All of our approval processes run through the corporate of f ice. We try to keep that very centralized so we know everyone s operating on the same basis, he says. There s always the chance you could have a rogue operator, but that s caught pretty quickly when you re central as opposed to branch to branch. Commonwealth s branch review team is bound by FINRA rules to examine its offices of supervisory jurisdiction at least once a year. Tolley says Commonwealth also makes a practice of visiting each of its RIAs, at a minimum, once every three years, and typically more of ten than that. He stresses the importance of site visits, though he also points out that a centralized oversight system and a well-staffed home office can help fill in the gaps. We are supervising through surveillance, through technology, transactions, communications every single day, Tolley says. We have just a myriad surveillance reports, exceptions reports that touch on a variety of issues. 5) Repeat Offenders There has been this year one more clear message from both FINRA and the SEC: If you re considering a recruit with repeated compliance violations, don t expect that advisor to clean up his act for you. In this year s guidance memo, FINRA offers a blunt warning to the brokers it oversees: Firms that hire or seek to hire high-risk brokers, including statutorily disqualif ied and recidivist brokers, can expect rigorous regulatory attention. The SEC also warns of recidivist representatives, saying that it will use their analytic capabilities to identif y individuals with a track record of misconduct and examine the f irms that employ them. Both Wainscott and Rollins say they would be unlikely to hire any advisors with a blemish on their record a hard line to be sure, but one that comes in consideration of the heightened regulatory scrutiny and reputational hit a rogue rep can bring to a f irm. Our industry is rather unique, Rollins says. If you make a mistake, you can be blackballed very, very quickly, just because it goes on your record. And before we interview anybody, we will go in and look at your record. by Kenneth Corbin 4
5 Corbin is a Financial Planning contributing writer based in Cambridge, Massachusetts, and Washington, D.C. The inf ormation provided is f or general inf ormation purposes only and is not intended to be legal, tax or investment advice. The inf ormation contained herein has been provided by sources other than Lord Abbett which are believed to be reliable; however Lord Abbett cannot guarantee the accuracy or completeness of this inf ormation. Investors should carefully consider the investment objectives, risks, charges and expenses of the Lord Abbett Funds. This and other important information is contained in the fund's summary prospectus and/or prospectus. To obtain a prospectus or summary prospectus on any Lord Abbett mutual fund, you can click here or contact your investment professional or Lord Abbett Distributor LLC at Read the prospectus carefully before you invest or send money. Not FDIC-Insured. May lose value. Not guaranteed by any bank. Copyright 2018 Lord, Abbett & Co. LLC. All rights reserved. Lord Abbett mutual funds are distributed by Lord Abbett Distributor LLC. For U.S. residents only. The information provided is not directed at any investor or category of investors and is provided solely as general information about Lord Abbett s products and services and to otherwise provide general investment education. None of the information provided should be regarded as a suggestion to engage in or refrain from any investment-related course of action as neither Lord Abbett nor its affiliates are undertaking to provide impartial investment advice, act as an impartial adviser, or give advice in a fiduciary capacity. If you are an individual retirement investor, contact your financial advisor or other fiduciary about whether any given investment idea, strategy, product or service may be appropriate for your circumstances. 5
Roth Recharacterization Repealed (Sort of)
RETIREMENT PERSPECTIVES Roth Recharacterization Repealed (Sort of) June 22, 2018 Brian Dobbis, QKA, QPA, QPFC, TGPC Director, Retirement Solutions 946 Views Recharacterization of Roth IRA conversions from
More informationTapping into Company-sponsored Retirement Plans While Still Employed
RETIREMENT PERSPECTIVES Tapping into Company-sponsored Retirement Plans While Still Employed February 12, 2015 Brian Dobbis, QKA, QPA, QPFC, TGPC Director, Retirement Solutions The rules governing in-service
More informationThe ABCs of RMDs. RMD Timing
RETIREMENT PERSPECTIVES The ABCs of RMDs April 29, 2015 Brian Dobbis, QKA, QPA, QPFC, TGPC Director, Retirement Solutions 125 Views Nearly everyone with a tax-deferred retirement account is required to
More information401(k) Loans: Whether a Borrower or a Lender, Beware
Retirement Perspectives 401(k) Loans: Whether a Borrower or a Lender, Beware April 4, 2014 Brian Dobbis, QKA, QPA, QPFC, T PGC Retirement Analyst, Institutional Investor Services A maze of rules applies
More informationGrowth Stocks: New Opportunities in a Trump Economy?
MARKET VIEW Growth Stocks: New Opportunities in a Trump Economy? February 20, 2017 2316 Views The prospect of earnings acceleration in cyclical sectors offers active managers the chance to uncover compelling
More informationHow Social Security Retirement Age Rules Impact Clients
PRACTICE MANAGEMENT How Social Security Retirement Age Rules Impact Clients March 15, 2017 512 Views Changes can substantially reduce the value of delaying widow(er) benefits for surviving spouses. This
More informationThe Appeal of Dividend-Growth Stocks
MARKET VIEW The Appeal of Dividend-Growth Stocks June 20, 2016 2543 Views Investors bracing for high volatility may want to consider high-quality, dividend-growth stocks which, like ballast in a boat,
More informationFloating-Rate Loans: No Need to Wait for LIBOR Day
MARKET VIEW Floating-Rate Loans: No Need to Wait for LIBOR Day August 29, 2016 4989 Views U.S. bank loans historically have offered attractive income, and the potential for portfolio diversification, in
More informationFive Key Advantages of Active Bond Management
FIXED-INCOME INSIGHTS Five Key Advantages of Active Bond Management April 3, 207 234 Views Investors focused on lower-fee strategies may wish to take a fresh look at the ways that active managers can add
More informationWhat a LIBOR Move Could Mean for Investors
FIXED-INCOME INSIGHTS What a LIBOR Move Could Mean for Investors August 11, 2016 Zane E. Brown Partner, Fixed Income Strategist 9343 Views Pending changes to U.S. money market funds appear to be pushing
More informationU.S. Fixed Income: A Refresher on Rising Rates
MARKET VIEW U.S. Fixed Income: A Refresher on Rising Rates April 10, 2017 5765 Views Here, we revisit the question of how U.S. taxable bonds may fare in the face of rising interest rates. In last week
More informationThe Expanding Legal Requirements for Rollover IRAs
The Expanding Legal Requirements for Rollover IRAs By Fred Reish Partner, Drinker Biddle & Reath LLP PlanAdvisorTools.com Provided compliments of Virtus Investment Partners The Expanding Legal Requirements
More informationMuni Matters: Seven Important Facts for Muni Investors
FIXED-INCOME INSIGHTS Muni Matters: Seven Important Facts for Muni Investors April 10, 2017 Daniel S. Solender, CFA Partner & Director 1763 Views An analysis of key data points for 2016 can provide a clearer
More informationSEC s Office of Compliance Inspections and Examinations: Examination Priorities for 2015
SEC s Office of Compliance Inspections and Examinations: Examination Priorities for 2015 Office of Compliance Inspections and Examinations ( OCIE ) The OCIE serves as the eyes and ears of the SEC. Conducts
More informationOverlapping examination priorities for 2018
2018 FINRA and SEC Examination Priorities Summary and Comparison February 2018 Overlapping examination priorities for 2018 A review of the 2018 Securities and Exchange Commission s (SEC) Office of Compliance
More informationDepartment of Labor (DOL) Fiduciary Rule
Department of Labor (DOL) Fiduciary Rule Updated for June 9, 2017 1. What is the DOL Fiduciary Rule? The DOL Fiduciary Rule is a regulation issued by the federal government. The regulation is intended
More informationFebruary 2015
Roundtable Road Show 2015 SEC Examination and Enforcement Trends for Investment Advisers February 2015 www.morganlewis.com Our Team Peter Chan, Chicago pchan@morganlewis.com +1.312.324.1179 Merri Jo Gillette,
More informationBest Practices Trump Regulatory Compliance
Best Practices Trump Regulatory Compliance Brian Hamburger, JD, CRCP President and CEO February 16, 2017 T3 Advisor Conference T3 Advisor Conference Cybersecurity Recruiting Equity Plan Design Succession
More informationTHE COMMONWEALTH ALLIANCE PROGRAM WHY IT ADDS UP TO WORK WITH US
THE COMMONWEALTH ALLIANCE PROGRAM WHY IT ADDS UP TO WORK WITH US The Bridgeway Group Matthew B. Dupon, CFP, AIF Sean A. Montgomery, CFP Theresa M. Mahoney 301 E Colorado Blvd, Suite 500 Pasadena, CA 91101
More information2015 Performance Report
2015 Performance Report Signals Site -> http://www.forexinvestinglive.com
More informationPENNY STOCK RISK DISCLOSURE STATEMENT
PENNY STOCK RISK DISCLOSURE STATEMENT The following information and statements are being provided by INSIGNEO Securities, LLC ( INSIGNEO or the Firm ) to provide important information concerning the risks
More informationHigh Yield: What's the Spread?
MARKET VIEW High Yield: What's the Spread? February 1, 2016 8719 Views Previous instances in which high-yield spreads exceeded 800 basis points represented attractive entry points into the U.S. high-yield
More informationMutual Fund Distribution Guide
Mutual Fund Distribution Guide Portland, Maine Berwyn, Pennsylvania Boston, Massachusetts Columbus, Ohio Table of Contents ntents Introduction...2 Intermediary Channel...3 Broker-Dealers... 3 Wirehouses...
More informationVALIC Financial Advisors, Inc.
Item 1 Cover Page VALIC Financial Advisors, Inc. FIRM BROCHURE Part 2A of Form ADV 2929 Allen Parkway, L3-20, Houston, Texas 77019 Telephone: (866) 544-4968 December 5, 2018 This brochure provides information
More informationModerator: Clifford Kirsch, Partner, Sutherland Asbill & Brennan LLP November 3-4, BISA Regulatory & Compliance Summit
Moderator: Clifford Kirsch, Partner, Sutherland Asbill & Brennan LLP November 3-4, 2014 BISA Regulatory & Compliance Summit Supervisory Issues Facing Bank Broker Dealers Sales to Seniors Qualified Plan
More informationMerrill Edge & You. Mutual Fund Disclosure Pamphlet Available
M615208431 Merrill Edge & You July 2015 Mutual Fund Disclosure Pamphlet Available Mutual Fund Investing at Merrill Lynch provides information about the fees and expenses related to mutual funds available
More informationAdvisor Access from Scottrade Investment Management
Advisor Access from Scottrade Investment Management Form ADV, Brochure Scottrade Investment Management 700 Maryville Centre Drive St. Louis, MO 63141 855.327.2253 www.scottradeinvestmentmanagement.com
More informationNew Employee FRS Enrollment Kit
New Employee FRS Enrollment Kit Welcome to the Florida Retirement System (FRS), your employer s retirement plan. As a new employee, you may not be retiring any time soon. But, you must choose between the
More informationEASY MAKE IT. Behavioral finance pioneer Richard Thaler on how the DC industry can continue to nudge participants and even plan sponsors
Photography credit: France Leclerc MAKE IT Behavioral finance pioneer Richard Thaler on how the DC industry can continue to nudge participants and even plan sponsors EASY toward better behavior 16 The
More informationTD BANK FINANCIAL GROUP LEADERSHIP VIEWS WITH BHARAT MASRANI FEBRUARY 3, 2010
TD BANK FINANCIAL GROUP LEADERSHIP VIEWS WITH BHARAT MASRANI FEBRUARY 3, 2010 DISCLAIMER THE INFORMATION CONTAINED IN THIS TRANSCRIPT IS A TEXTUAL REPRESENTATION OF THE TORONTO-DOMINION BANK S ( TD ) LEADERSHIP
More informationWhy Hire a Fiduciary Advisor?
Why Hire a Fiduciary Advisor? Introduction Making long-term decisions about money can be difficult and even a little scary. Many people turn to an advisor for help with their financial decisions. Many
More informationRemarks From the 2015 FINRA Annual Conference
Remarks From the 2015 FINRA Annual Conference Richard G. Ketchum Chairman and Chief Executive Officer Washington, DC MAY 27, 2015 As prepared for delivery. I would like to discuss with you today the important
More informationOCIE to Target Adviser Payments for Fund Distribution, Funds with Alternative Strategies and New Advisers
February 22, 2013 OCIE to Target Adviser Payments for Fund Distribution, Funds with Alternative Strategies and New Advisers By Jay G. Baris and Kelley A. Howes In an attempt to increase transparency, strengthen
More informationFinancial Industry Developments
2016 INVESTMENT MANAGEMENT CONFERENCE Financial Industry Developments Nicholas S. Hodge, Partner, Boston Michael W. McGrath, Partner, Boston Copyright 2016 by K&L Gates LLP. All rights reserved. Hedge
More informationHuman-Centric Investing Podcast
Human-Centric Investing Podcast November 2, 2018 Episode 22: Retirement Plan Trends: Interview with Patrick Murphy, CEO at John Hancock Retirement Plan Services (Part Two) Host: John Diehl, Sr. Vice President,
More informationRegulatory Developments
Regulatory Developments Dan Kahl Office of Investment Adviser Regulation Division of Investment Management U.S. Securities and Exchange Commission Cliff Kirsch Sutherland Asbill & Brennan Steven W. Stone
More informationWe believe the election outcome will not interfere with your ability to achieve your long-term financial goals.
Dear Client: On Jan. 20, Donald Trump, as you know, will become the 45th president of the United States. This letter provides you our analysis of what the election s outcome means for you. Let me summarize
More information2015 Performance Report Forex End Of Day Signals Set & Forget Forex Signals
2015 Performance Report Forex End Of Day Signals Set & Forget Forex Signals Main Site -> http://www.forexinvestinglive.com
More informationThe SEC s ReTIRE Initiative: An Examination Initiative Focused on Products and Services Provided to Retail Investors Saving for Retirement
The SEC s ReTIRE Initiative: An Examination Initiative Focused on Products and Services Provided to Retail Investors Saving for Retirement By Robert L. Tuch Introduction Robert L. Tuch is a senior consultant
More informationJim Mitchel Shannon O Keefe. November 2010
2010 Membership Survey Jim Mitchel Shannon O Keefe November 2010 Contents page Objective 3 Summary 4 Support for NAIFA s Positions 8 Survey Administration 10 Membership Survey Results 11 Consumer Survey
More informationFind Private Lenders Now CHAPTER 10. At Last! How To. 114 Copyright 2010 Find Private Lenders Now, LLC All Rights Reserved
CHAPTER 10 At Last! How To Structure Your Deal 114 Copyright 2010 Find Private Lenders Now, LLC All Rights Reserved 1. Terms You will need to come up with a loan-to-value that will work for your business
More information2015 Performance Report
2015 Performance Report Signals Site -> http://www.forexinvestinglive.com
More informationA SEISMIC SHIFT HOW THE DOL S FIDUCIARY RULES WILL UPEND FINANCIAL ADVICE AND WHAT ADVISORS SHOULD BE DOING RIGHT NOW TO PREPARE SPONSORED BY
A SEISMIC SHIFT HOW THE DOL S FIDUCIARY RULES WILL UPEND FINANCIAL ADVICE AND WHAT ADVISORS SHOULD BE DOING RIGHT NOW TO PREPARE SPONSORED BY O n October 7, Merrill Lynch announced the end of commissionbased
More informationIncome for Life #31. Interview With Brad Gibb
Income for Life #31 Interview With Brad Gibb Here is the transcript of our interview with Income for Life expert, Brad Gibb. Hello, everyone. It s Tim Mittelstaedt, your Wealth Builders Club member liaison.
More informationTRANSAMERICA FINANCIAL ADVISORS, INC. FORM ADV PART 2A, APPENDIX 1
ITEM 1 COVER PAGE TRANSAMERICA FINANCIAL ADVISORS, INC. FORM ADV PART 2A, APPENDIX 1 TRANSAMERICA ONE WEALTH MANAGEMENT PLATFORM BROCHURE 570 CARILLON PARKWAY ST. PETERSBURG, FLORIDA 33716-1202 (727) 299-1800
More informationRegulatory Notice 11-54
Regulatory Notice 11-54 Branch Office Inspections FINRA and the SEC Issue Joint Guidance on Effective Policies and Procedures for Broker-Dealer Branch Inspections Executive Summary FINRA and the Securities
More informationQuestions to Ask Your Financial Advisor
Questions to Ask Your Financial Advisor About Him or Her Are you acting in a fiduciary capacity? If not, why not? What is your education and background? How long have you been practicing? Are you registered
More informationFINRA Conference 2017
FINRA Conference 2017 Takeaways: (from Robert Cook, CEO FINRA) Regulatory landscape is much more complex than ever before with more overlap Best Interest is here to stay Cost of ownership is lower and
More information401(k) Action Steps To Take Now
in order to take charge of your financial life HAVE YOU EVER SWITCHED JOBS? Research shows the average American employee switches jobs 11 times before retiring. 1 Job changes means many Americans have
More informationBy JW Warr
By JW Warr 1 WWW@AmericanNoteWarehouse.com JW@JWarr.com 512-308-3869 Have you ever found out something you already knew? For instance; what color is a YIELD sign? Most people will answer yellow. Well,
More informationTen Reasons to Roll Over Into Your Plan Versus an IRA Michael Viljak, Manager, Advisor Development
April 2019 Ten Reasons to Roll Over Into Your Plan Versus an IRA Michael Viljak, Manager, Advisor Development Do you have employees in a prior employer s retirement plan? Should they transfer these assets
More informationPart 2A of Form ADV: Firm Brochure
Part 2A of Form ADV: Firm Brochure 824 Meeting Street West Columbia, South Carolina 29169 Telephone: 803-739-6311 Email: atodd@assetmgtplanning.com Web Address: www.assetmgtplanning.com 6/20/2017 This
More informationMonthly Treasurers Tasks
As a club treasurer, you ll have certain tasks you ll be performing each month to keep your clubs financial records. In tonights presentation, we ll cover the basics of how you should perform these. Monthly
More informationPlan Participants: The Key to Developing Your Retirement Business
WORKSITE FINANCIAL SOLUTIONS Plan Participants: The Key to Developing Your Retirement Business Worksite Financial Solutions White Paper Executive Summary Table of Contents: 3 The Trouble with the Status
More informationWhat Matters to You Matters to Us
EARNING YOUR TRUST. WORKING TOWARDS YOUR SUCCESS. SHARING YOUR VISION. What Matters to You Matters to Us Relationships are an integral part of the social and business fabrics that form our lives. The depth
More informationYour Risk Management Toolkit. Kevin Larson, Chief Compliance Officer, Cetera Investment Services
Your Risk Management Toolkit Kevin Larson, Chief Compliance Officer, Cetera Investment Services Agenda Recap of Enforcement Actions FINRA Exam Priorities Banking Priorities How Best to Protect Your Financial
More informationTHE FIDUCIARY STANDARD: WHAT COULD CHANGE TO THE DOL STANDARD MEAN TO YOU
THE FIDUCIARY STANDARD: WHAT COULD CHANGE TO THE DOL STANDARD MEAN TO YOU LISA BLEIER, MANAGING DIRECTOR AND ASSOCIATE GENERAL COUNSEL APRIL 30, 2014 Overview Current Law o ERISA o Securities Laws Dodd
More informationUSAA s Unique Strategy for the Advisor Market
USAA s Unique Strategy for the Advisor Market May 15, 2017 by Robert Huebscher Keith Sloane serves as head of third-party distribution for USAA Investments. Mr. Sloane previously served as a senior vice
More informationHow Should Hedge Fund Managers Approach the Identification, Prevention, Detection, Handling and Correction of Trade Errors? (Part One of Three)
hedge LAW REPORT fund law and regulation Trade Errors How Should Managers Approach the Identification, Prevention, Detection, Handling and Correction of Trade Errors? (Part One of Three) By Jennifer Banzaca
More informationHow Studying SEC Enforcement Trends Can Help Hedge Fund Managers Prepare for SEC Examinations and Investigations
EXAMINATIONS How Studying SEC Enforcement Trends Can Help Hedge Fund Managers Prepare for SEC Examinations and Investigations By Michael Washburn In a recent interview with The Hedge Fund Law Report, Patricia
More informationEarning Your Trust. Sharing Your Vision. What Matters to You Matters to Us
Earning Your Trust. Working Towards Your Success. Sharing Your Vision. What Matters to You Matters to Us Relationships are an integral part of the social and business fabrics that form our lives. The depth
More informationFINRA Regulatory Notice 17-20: Retrospective Rule Review Outside Business Activities and Private Securities Transactions
By Electronic Mail (pubcom@finra.org) Office of the Corporate Secretary FINRA 1735 K Street, NW Washington, DC 20006-1506 Re: FINRA Regulatory Notice 17-20: Retrospective Rule Review Outside Business Activities
More informationCURRENTS Regulatory Scrutiny on Wrap Fee Programs Not Such a Wrapper s Delight
SPECIAL REPRINT CURRENTS Regulatory Scrutiny on Wrap Fee Programs Not Such a Wrapper s Delight By Michael Abbriano Since the first wrap fee program was launched in 1975, their popularity has grown exponentially,
More informationSOLVING THE CHALLENGES OF SMALL AND MID-SIZED RETIREMENT PLANS
SOLVING THE CHALLENGES OF SMALL AND MID-SIZED RETIREMENT PLANS SPONSORED BY A GROWTH OPPORTUNITY IN MANAGING FIDUCIARY RESPONSIBILITY 1 SOLVING THE CHALLENGES OF SMALL AND MID-SIZED RETIREMENT PLANS The
More informationFind the retirement solution that s right for your business and employees
RETIREMENT SOLUTIONS FOR BUSINESSES Find the retirement solution that s right for your business and employees Understand the options available through UnionBanc Investment Services 1. As a business owner,
More informationWRITTEN SUPERVISORY PROCEDURES
WRITTEN SUPERVISORY PROCEDURES Revised 10/2007 Authorized Approval Signature: Printed Name & Title: Date: Jessica Gilday, Managing Member/Compliance Officer This Manual is effective from the date approved
More informationThe DOL Fiduciary Rule. Questions & answers by Fred Reish. Retirement Plan Solutions. Content provided by. Compliments of
Retirement Plan Solutions Content provided by The DOL Fiduciary Rule by Fred Reish Compliments of The law and analysis contained in these questions and answers are current as of June 2016, are general
More information11 Biggest Rollover Blunders (and How to Avoid Them)
11 Biggest Rollover Blunders (and How to Avoid Them) Rolling over your funds for retirement presents a number of opportunities for error. Having a set of guidelines and preventive touch points is necessary
More informationEdward Jones Transitional Retirement Account Brochure
Edward Jones Transitional Retirement Account Brochure as of March 29, 2018 Edward Jones 12555 Manchester Road St. Louis, MO 63131 800-803-3333 www.edwardjones.com Item 1: Cover Page This wrap fee program
More informationThe Easiest Way To Make Money In Real Estate
The Easiest Way To Make Money In Real Estate Introduction Here we go You re interested in making money in real estate. That s why you re reading this report. I know your goal You want a better return than
More informationIncome Fund Update: Building Resiliency in Volatile Markets
Income Fund Update: Building Resiliency in Volatile Markets January 28, 2019 by Dan Ivascyn, Alfred Murata of PIMCO SUMMARY During the fourth quarter of 2018, high quality assets were the key drivers of
More informationFirm Disclosure Brochure Item 1 Form ADV Part 2A March 29, 2018 Page 1 of 8. Material Changes Item 2. Table of Contents Item 3
Firm Disclosure Brochure Item 1 Page 1 of 8 Harold Dance Investments 360 North Main Street Logan, Utah 84321 435-752-8484 Disclaimer This brochure provides information about the qualifications and business
More informationWhat to Expect from the U4 and U5 Filing Process
What to Expect from the U4 and U5 Filing Process This is another installment in our What to Expect webcast series on FINRA s regulatory processes. It focuses on the process for filing Uniform Applications
More information6025 S. Quebec St., Suite 170 Centennial, CO
HIGHLIGHTS INCLUDE: Powerful information that could potentially save you thousands in taxes and fees. Tips to help put you one step ahead in your retirement preparations. Critical mistakes that cannot
More informationHow Should Advisors Be Charging Now?
PRACTICE MANAGEMENT How Should Advisors Be Charging Now? June 25, 2015 137 Views The venerable model of charging a percentage of assets under management faces challenges from a variety of contenders, including
More informationInterview With IRA Expert Ed Slott
Interview With IRA Expert Ed Slott By Robert Brokamp September 2, 2010 Motley Fool s Rule Your Retirement Certified public accountant Ed Slott, the author of five books, is considered one of America's
More informationOn Obtaining OSFI Approval
Strategic Information Technology Limited On Obtaining OSFI Approval Strategic Information Technology sits down with financial veteran Philip Buxton to ask a few questions about the OSFI approval process.
More informationThe DOL s Fiduciary Rule: Where It s Going
SM PlanAdvisorTools.com The DOL s Fiduciary Rule: Where It s Going By Fred Reish - Partner, Drinker Biddle & Reath LLP SM The DOL s Fiduciary Rule: Where It s Going by Fred Reish Partner, Drinker Biddle
More informationFiduciary Rule: Initial Impact Analysis
Fiduciary Rule: Initial Impact Analysis September 7, 2017 Presented To: Study Objectives and Methodology Ongoing Monitoring of Fiduciary Rule The U.S. Chamber of Commerce has committed to monitoring the
More informationBackground and Impact on Retirement Savers
Protecting Retirement Savings FAQs as released by the U.S. Department of Labor in April 2016, except for annotations in red added by NELP in June 2017 NELP Note: On February 3, 2017, President Trump directed
More informationHow to Control Your Own Destiny, Generate More Fees and Explode Your Wealth By Structuring Your Own Deals Using Little of Your Own Money WEALTH
How to Control Your Own Destiny, Generate More Fees and Explode Your Wealth By Structuring Your Own Deals Using Little of Your Own Money A Business Designed for Brokers That ll Increase Your Fees and Explode
More informationDepartment of Labor Fiduciary Rule
Department of Labor Fiduciary Rule Hillel Cohn March 8, 2017 MORRISON & FOERSTER LLP 2017 mofo.com Status of the DOL Fiduciary Rule Adopted by the DOL in April 2016 Became effective in June 2016, with
More informationRETIREMENT A NEW BEGINNING
RETIREMENT A NEW BEGINNING 2 YOUR RETIREMENT. YOUR Contents More choice, more freedom, more decisions 4 Getting ready for retirement 6 Understanding what happens in the event of your death 7 Navigating
More informationIntroduction Pennsylvania Ave. NW Suite 700 Washington, D.C financialservices.org
Statement of Robin Traxler, Senior Vice President and Deputy General Counsel Financial Services Institute before the SEC Investor Advisory Committee December 13, 2018 Washington, D.C. Discussion Regarding
More informationRetirement Plan Advisors, LLC Client Brochure
Retirement Plan Advisors, LLC Client Brochure Updated March 31, 2018 This brochure provides information about the qualifications and business practices of Retirement Plan Advisors, LLC. If there are any
More informationShort Selling Stocks For Large And Fast Profits. By Jack Carter
Short Selling Stocks For Large And Fast Profits By Jack Carter 2017 Disclaimer: No financial advice is given or implied. Publisher is not registered investment advisor or stockbroker. Information provided
More informationOne of the industry s Fastest Growing RIAs
One of the industry s Fastest Growing RIAs www.pomplanning.net The growth of POM Planning is truly amazing. Its unique low drawdown risk platform has made it one of the fasted growing RIAs in the entire
More informationTHE ULTIMATE IPO HANDBOOK. W h a t y o u n e e d t o k n o w a b o u t i n v e s t i n g i n I P O s
THE ULTIMATE IPO HANDBOOK W h a t y o u n e e d t o k n o w a b o u t i n v e s t i n g i n I P O s Disclaimer This document has been prepared by On-Market BookBuilds Pty Ltd (the Discloser ). This document
More informationForm ADV Part 2 Brochure Dated March 29, 2018
Form ADV Part 2 Brochure Dated March 29, 2018 Goelzer Investment Management, Inc. 111 Monument Circle, Suite 500 Indianapolis, IN 46204 Phone Number (317) 264-2600 www.goelzerinc.com This Form ADV Part
More informationHedge and Private Fund Regulation After Dodd-Frank March 11, 2011
Hedge and Private Fund Regulation After Dodd-Frank March 11, 2011 Kurt Decko Matt Mangan Mark Perlow SF-233861 Copyright 2010 by K&L Gates LLP. All rights reserved. Agenda Overview Removal of private adviser
More informationImportant Information on Penny Stocks
Important Information on Penny Stocks This statement is required by the U.S. Securities and Exchange Commission (SEC) and contains important information on penny stocks. Your broker-dealer is required
More informationYour Additional Voluntary Contribution (AVC) fund guide
1 Your Additional Voluntary Contribution (AVC) fund guide For members of Pace Complete April 01 1 1 1 Welcome to your AVC fund guide for members of Pace Complete This fund guide is relevant to you if you
More informationPremiere Select IRA Application
Branch Prefix FOR BRANCH USE ONLY Account Number RR RR2 Agency Premiere Select IRA Application 1. Registration/IRA Type Check as applicable. Check one. IRA Traditional Roth Rollover SEP IRA BDA:* Are owners
More informationHow do I become an HD Vest Advisor? EDUCATION AND LICENSING
How do I become an HD Vest Advisor? EDUCATION AND LICENSING For more than 30 years, we ve remained steadfast in our mission to give every American the opportunity to have access to a skilled financial
More informationRetirement Income: The New Perspective for 401(k) Plans
Retirement Income: The New Perspective for 401(k) Plans Provided compliments of Virtus Investment Partners PlanAdvisorTools.com Retirement Income: The New Perspective for 401(k) Plans Background and Introduction
More information4 BIG REASONS YOU CAN T AFFORD TO IGNORE BUSINESS CREDIT!
SPECIAL REPORT: 4 BIG REASONS YOU CAN T AFFORD TO IGNORE BUSINESS CREDIT! Provided compliments of: 4 Big Reasons You Can t Afford To Ignore Business Credit Copyright 2012 All rights reserved. No part of
More informationCONFLICT OF INTEREST FAQS (PART I- EXEMPTIONS)
CONFLICT OF INTEREST FAQS (PART I- EXEMPTIONS) U.S. Department of Labor Employee Benefits Security Administration October 27, 2016 New Exemptions and Amendments to Existing Exemptions Under the Employee
More informationTRANSAMERICA FINANCIAL ADVISORS, INC.
ITEM 1 COVER PAGE TRANSAMERICA FINANCIAL ADVISORS, INC. Transamerica Financial Advisors Division FORM ADV PART 2A APPENDIX 1 570 CARILLON PARKWAY ST. PETERSBURG, FLORIDA 33716-1202 (800) 322-7161 HTTPS://TFA.TRANSAMERICA.COM
More informationUBS CLIENT RELATIONSHIP AGREEMENT
UBS CLIENT RELATIONSHIP AGREEMENT Terms and Conditions of your current and future Accounts This Client Relationship Agreement, as well as the Agreements and Disclosures booklet and the agreements for the
More information