Practical Trade Desk Oversight
When people think of an Investment Adviser, their first notion would likely be of the trading desk. The desk is where the “rubber meets the road” in the investment world. All other activities within the IA serve to support trading activity and the selection of one investment possibility over another. It is on the trading desk that the ideas of an Investment Committee or a portfolio manager come to life. The trading desk is where the theory of returns becomes a reality. As such, the trading desk is a place of great importance and must be supervised accordingly.
Pressures and Changes Around SEC Examinations
Since the Madoff Ponzi scheme unraveled, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has been under the microscope. Wide criticism has been leveled about how the SEC has selected advisers for examination and how the SEC conducts examinations of investment advisers.
The SEC’s responses have included new examination initiatives (primarily involving third-party asset verification of client funds and securities), efforts to increase the expertise of examiners, the appointment of the new OCIE Director Carlo di Florio on January 4, 2010, and a re-evaluation of how OCIE Staff identifies risk…
Records Management for Investment Advisers
An investment adviser posts a seemingly innocuous comment to his firm’s social networking profile page, congratulating his colleagues on a successful year selecting investments. Another adviser, upon realizing that one of her long-time clients has recently moved and did not receive the firm’s new Form ADV brochure, quickly sends an e-mail to the client and attaches the requested documents.
Considerations for Outsourcing Compliance
In the post-Dodd-Frank regulatory world, investment advisers seeking to meet the expectations of the Securities and Exchange Commission (“SEC”), or of other regulators, face a common challenge:
How do we manage our business, stay on top of all the regulatory requirements and changes, and still meet our day-to-day compliance responsibilities?
This article discusses the factors investment adviser firms must consider when determining whether to tackle regulatory and compliance issues internally or outsource aspects of their compliance program.
Demystifying the Cloud: Electronic Storage of Records by Investment Advisors in the Cloud Computing Era
Whether technologically-savvy or not, investment advisers of all backgrounds appear keenly interested in latest industry trend – the migration to cloud computing. However, calling it the latest trend is a bit of a misnomer. At its most basic level, the “cloud” refers to the Internet, a global network of interconnected computers and devices that has its roots in 1960’s-era ARPANET, a primitive network created by the Advanced Research Projects Agency of the U.S. Department of Defense. The “cloud” therefore is not a new concept, but rather recent nomenclature for the abstract, black box conceptualization of the Internet and all of the computers, servers, and devices connected to it.
Friend-ing Social Media: Considerations for Investment Advisers Use of Social Media Networks
Technology has quickly infiltrated all aspects of our lives. Whether it’s built-in GPS technology in mobile devices or the proliferation of applications that help us shop for groceries, technology is everywhere. According to Nielsen’s “State of the Media: The Social Media Report — Q3 2011” study, social networks and blogs continue to dominate Americans’ time online, and Americans spend more time on Facebook than they do on any other U.S. website.1 The study provides an interesting snapshot of the current social media landscape in the U.S. and other major markets.