On March 19, 2025, the SEC made two significant updates to the Marketing Rule's FAQ page. DWT discussed the SEC's recently adopted Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act of 1940) in our 2024 post, and...more
After two decades and three proposed rulemakings on whether investment advisers should have anti-money laundering (AML) and countering the financing of terrorism (CFT) program requirements and attempting to identify the...more
10/8/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
Corporate Counsel ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
For the second time in a decade, the Department of Labor (DOL) attempted to expand the reach (and requirements) of the Employee Retirement Income Security Act of 1974 (ERISA). On April 23, 2024, DOL succeeded and announced...more
5/7/2024
/ Benefit Plan Sponsors ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Exemptions ,
Fiduciary Rule ,
Individual Retirement Account (IRA) ,
Investment ,
Investment Adviser ,
New Rules ,
Prohibited Transactions ,
Retirement Plan
The use of artificial intelligence and machine learning technology solutions ("AI") is becoming increasingly common in all industries, including the registered investment adviser ("RIA") space. A recent survey by AI platform...more
5/6/2024
/ Artificial Intelligence ,
Automation Systems ,
Broker-Dealer ,
Compliance ,
Disclosure Requirements ,
Enforcement ,
Fraud ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Machine Learning ,
Portfolio Managers ,
Securities and Exchange Commission (SEC)
Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more
1/19/2024
/ Compliance ,
Conflicts of Interest ,
Cryptoassets ,
Cryptocurrency ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement Actions ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Marketing ,
Policies and Procedures ,
Private Funds ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934