Monday, September 21, 2009


Cosgrove Law members attended the North American Securities Administrators (NASAA) annual conference last week. The conference provided us with great opportunities to interact with state regulators from around the country and directly hear from these regulators about their issues. They focused on a wide variety of topics involving broker-dealers and investment advisers because the regulatory changes being discussed at the federal level was on everyone’s mind. Where these discussions will lead and what effect any regulatory changes might have on everyone is not known at this time. What we did take away is that all of us need to be aware of the changes being proposed e.g. the Consumer Financial Protection Agency, understand the implications to our businesses, and be ready to implement best practices to ensure compliance.

Blue Sky Compliance for Investment Advisers-NASAA’s findings from Audit Sweep

NASAA coordinated a comprehensive audit sweep by the states of Investment Advisers this year. At the conference, they presented their findings and the deficiencies they most often found. Registration, Books and Records, Unethical Business Practices, Supervision, Privacy policy and Fees and Custody were the most frequent violations uncovered, but inaccurate ADV filings were the number one deficiency found. We can assume that States will now be closely looking at Investment Adviser ADV filings. Are your ADV filings compliant? Is your firm ready to face a regulator’s scrutiny? Are you aware of FINRA’s recent releases for changes to the IARD/CRD system? If not, or you just want to ensure your current practices are compliant, contact us to review and analyze your firm’s registration practices.

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