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Articles tagged "Les Abromovitz"


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Les Abromovitz: The SEC and state securities regulators want to prove they are aggressively overseeing RIAs.

Lost in limbo: How and why compliance officers can seem to thwart RIA marketing efforts

CCOs have valid reasons for poring over the content of any proposed articles coming from their firm -- but they owe you a quick response

February 22, 2012 at 3:52 AM

Les Abromovitz: "Social plug-ins,” such as the “like” feature, might be viewed by examiners as a testimonial.

Think about compliance before sending or posting those articles you read

A new SEC alert gives updated guidance regarding the pitfalls of using social media

January 23, 2012 at 4:40 PM

Les Abromovitz: You won't score points with examiners by having superfluous or irrelevant policies and procedures.

Recent SEC enforcement actions make annual policies and procedures exams even more important

Sprucing up your compliance manual early and often can prevent the SEC leaving coal in your Christmas stocking

January 5, 2012 at 4:59 AM

Les Abromovitz: A word or two can make the difference between a compliant video and one that is potentially misleading.

Why RIA videos are especially fraught with regulatory pitfalls

The productions are expensive so check with the CCO before rolling the cameras

December 5, 2011 at 4:21 AM

Les Abromovitz:  [Soft dollar use] may affect the best execution of securities transactions and might cause the client to pay more than the lowest-available commission.

RIAs need to take a hard look at their use of soft dollars

Some advisors are landing in hot water with the SEC

November 11, 2011 at 5:14 AM

Les Abromovitz: Investment advisors should avoid selective amnesia in their newsletters.

Advisor newsletters: Compliance-wise, all news may not be fit to print

Even a photograph of a client may be viewed as a testimonial

October 19, 2011 at 3:11 AM

Les Abromovitz: Ironically, the RIA that received notice of this desk audit was not required to be registered in the state conducting the examination.

RIAs switching to state registration may be examined by a second regulator, too

The audit may come remotely from a state where the advisor doesn't have a place of business

September 22, 2011 at 2:54 AM

Les Abromovitz: Avoid statements that expressly state or imply that you and your firm are in a class by yourself.

Examiners may ask “Says who?” about your advertisements

RIAs may run afoul of the SEC by using superlatives like "unparalleled" and "unique"

June 21, 2011 at 2:23 PM

Les Abromovitz: In a discussion of this issue, one attorney at NCS argued that the individual was giving the Facebook page a thumbs-up, not the advisory firm. It remains to be seen if regulators will make that distinction.

Why compliance experts are apt to dislike Facebook

When does a click constitute an endorsement?

May 13, 2011 at 1:08 PM

Les Abromovitz: Resolving these issues at the firm level reduces the risk that someone will take their complaint to regulators.

Potential whistleblowers have little to lose and millions to gain with the SEC's reward system

Here's how to keep complaints from turning into tip-off phone calls

April 14, 2011 at 1:16 PM

Les Abromovitz suggests that advisors file their ADV forms even if they're not happy with the content: 'You are at least making a good faith effort to be compliant.'

How suitable are your investment strategies? The SEC cares, a lot.

New ADV form heightens attention to the issue

March 30, 2011 at 2:19 PM

Les Abromovitz: The fact that another adviser is engaging in the same conduct does not make it compliant. For example, you won’t help your cause by showing examiners other RIA websites that are just as noncompliant as yours is.

What not to do during a state or SEC audit

The four tempting -- but ultimately counterproductive -- tacts advisors sometimes take

March 8, 2011 at 2:37 PM

The mere fact that clients give you their e-mail address should not be construed as consent to delivery of important documents.

How to avoid that fatal blow to client communication

Keep tweets, text messages and e-mails in their proper places

February 14, 2011 at 3:03 PM

Les Abromovitz: Glowing remarks by clients may count as testimonials.

Considering hosting a radio show? The SEC may tune in.

Radio programs and commercials pose compliance complications. Disclosure helps.

January 20, 2011 at 2:30 PM

Les Abromovitz: Recently, one RIA firm that I work with claimed to have created hundreds of unique solutions. Those kinds of claims invite a securities examiner to ask for proof that the firm’s solutions are truly out of the ordinary.

The marketing naughty and nice list

Catchwords and strategies likely to draw regulators' ire -- and others that pass anyone's test

December 23, 2010 at 2:51 PM

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