Comprehensive consulting for investment advisors, broker-dealers and private funds.
Update for Washington State Advisers
We attended the DFI’s 2019/2020 Investment Adviser Seminar in Seattle on February 12. It was a great help to hear from Joanne Jones, Kristen Standifer, and Mark Kissler about rule changes and the types of violations they continue to see during their examination and enforcement processes. We’re not going to regurgitate the regulations.......Read More

Form CRS: No Need for Panic (Yet)
As you probably know if you work with retail clients, there’s a new disclosure (referred to as Form CRS, ADV Part 3, or the “relationship summary”) SEC registrants will have to start delivering by June of next year (state advisers are so far Unless, of course, that date gets delayed. Which hardly ever happens with complex new requirements…......Read More

Don't "Resolve" Conflict (Manage It!)
Conflict is one of the hardest things leaders deal with. Most people find conflict pretty scary and few of us are taught how to handle it well. A common corporate response to conflict seems to be: “bury your head in the sand till things are so horrible you have to react.” That leads to bad morale, declining productivity, and high turn......Read More

Practical Tips for Cyber and Privacy Protection
The recent OCIE Risk Alert on compliance issues related to privacy and safeguard policies is notable for how basic the problems are that the SEC continues to find. The #1 most-frequent violation cited in the Alert was simply failure to provide the firm’s priv......Read More

When "Best Practice" Isn't
I was out to dinner recently and, after the waiter carefully described the specials - a filet mignon or a delightful-sounding pork loin - my husband asked what she liked better. The waiter paused and then said, “Well, actually, I’m vegan, so I haven’t tried them, but I bet they’re really good.” I bet they are! And her opinion was entir......Read More

Annual Update Time!
This is the time of year to pay close attention to your disclosures and make sure your ADV accurately describes your business, especially your services, compensation, and conflicts of interest. It’s especially important to take a careful look if you’ve never had a regulatory examination. One of the most common things we see is advisors who got......Read More