Navigating Model Fees and Net Performance in Investment Advertising Compliance Navigating Model Fees and Net Performance in Investment Advertising Compliance Investment advisers face complex rules when advertising portfolio performance, especially regarding how fees are presented. A key question is whether advisers can show net performance based on actual fees charged historically when the fees expected to be charged to prospective clients are higher. This issue touches on Ru

Navigating Compensation Regulations for Alternative Investments: Do's and Don'ts for RIAs Alternative investments such as private funds, private placements, non-traded REITs, and private credit have become increasingly popular among clients seeking diversification and higher returns. However, these investment types come with complex regulatory challenges, especially when it comes to compensation paid by issuers to Registered Investment Advisers (RIAs). Both the Securities and

Understanding the SEC's Proposed Changes to Small Adviser Definitions and Their Impact on the Industry The Securities and Exchange Commission (SEC) recently proposed updates to the way it defines “small advisers” under the Regulatory Flexibility Act (RFA). While these changes may seem technical, they carry significant implications for investment advisers, especially smaller firms. This post breaks down the SEC’s proposal, explains why it matters, and explores how it could aff

Mastering Fee Disclosures: A Guide for RIAs to Ensure Client Trust and Compliance Clear and accurate fee disclosures are essential for Registered Investment Advisers (RIAs) to build trust with clients and meet regulatory requirements. The Securities and Exchange Commission (SEC) and state regulators have increased their focus on how fees are described, calculated, and charged. This means RIAs must review and improve their fee disclosure practices to avoid enforcement actions,

Registered Investment Advisers (RIAs) face many regulatory requirements, but few are as crucial as understanding Regulatory Assets Under Management (RAUM). This figure not only determines whether an adviser must register with the Securities and Exchange Commission (SEC) or state regulators but also affects ongoing disclosure and reporting duties. Getting RAUM right is essential for compliance and helps regulators evaluate the size and risk profile of advisory firms. This post

The role of the Chief Compliance Officer (CCO) in investment advisory firms has never been more critical. As regulatory scrutiny intensifies, the Securities and Exchange Commission (SEC) has clarified when and how CCOs may face personal liability. While CCOs are not meant to be scapegoats for firm-wide compliance failures, recent SEC enforcement actions reveal clear boundaries around their responsibilities and accountability. This post explores what the SEC has communicated i

Essential Guide to the Annual ADV Update for RIAs by March 31 Each year, Registered Investment Advisers (RIAs) must submit an annual update to their Form ADV. This filing is a key regulatory requirement that keeps your firm’s information current and transparent for both regulators and clients. The deadline to complete this update is March 31 or within 90 days after your fiscal year-end. Missing this deadline can lead to penalties and damage your firm’s reputation. This guide

Increasing Investor Opportunities Act The Increasing Investor Opportunities Act (IIOA) marks a significant change in how private market investments are regulated in the United States. For decades, access to private offerings has been limited by strict definitions of who qualifies as an accredited investor, primarily based on wealth. The IIOA challenges this approach by expanding eligibility criteria to include education, credentials, and experience. This shift aims to open pr

'Twas the Nightmare Before Year-End: A Compliance Tale 'Twas the week before year-end, and all through the firm, Not a document was...

Clear and accurate fee disclosures are essential for building client trust and meeting regulatory expectations. For Registered Investment Advisers (RIAs), fee transparency isn’t just good business—it’s a legal requirement. With the SEC and state regulators placing increased scrutiny on how fees are described, calculated, and charged, now is the time to revisit your firm’s disclosure practices. --- ### 💡 Why Fee Disclosure Matters Clients need to understand how they’re being