Compliance and Consulting

Update on PCAOB Inspection of Broker-Dealers

In August 2011, the interim inspection program of auditors was implemented due to new authority given to the Public Company Accounting Oversight Board (PCAOB) over auditors of SEC-registered broker-dealers by the Dodd Frank Wall Street Reform and Consumer Protection Act.

The PCAOB issued its first two progress reports…more

Proposed Accounting Standards Update on NAV Per Share

The Financial Accounting Standards Board (FASB) has issued a proposed Accounting Standards Update (820), “Fair Value Measurement (Topic 820): Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent).” As a reminder, comments on the proposed ASU are due January 15, 2015.

What Led…more

A Reminder of the Changes to Broker-Dealer Reporting

Several years ago, the Securities and Exchange Commission undertook a project to revise the reporting requirements of broker-dealers. As many of our clients are getting ready for their annual audit, we thought now was a good time to revisit the revised reporting requirements for broker-dealers.

In June 2011…more

An Update to 408(b)(2) and Its Impact on Investment Advisors

The Department of Labor (DOL) recently put forth a proposed amendment to its rule, Reasonable Contract or Arrangement Under Section 408(b)(2) – Fee Disclosure, which initially became effective July 1, 2012.

Under the original rule, covered service providers were required to provide certain disclosures, some of which are described…more

Investment Fees: Are You Charging the Right Amount?

In today’s marketplace, investment management fees vary widely from one product to another, as well as from one client to another. Fee calculations range from simple to quite complex.

In their most basic form, management fees are a flat percentage of assets under management. However, investment advisors and clients…more

Are You in Compliance with SEC Custody Rules?

After the barrage of investment frauds several years ago, the SEC came under intense pressure to update its rules protecting investors. The SEC responded by issuing what is commonly referred to as the “custody rules.”

The custody rules indicate that if an investment manager has custody of client funds, they…more

What Investment Advisors Need to Know About 408(b)(2)

In December 2007, a proposed rule was published concerning the disclosures that must be furnished to plan fiduciaries in order for plan services to be considered “reasonable.” Following a public comment period, public hearing, and interim final rule published in July 2010, the final rule became effective July 1. This…more

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