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Carl Ayers

There have been several recent reports that SEC examiners appear to be giving out more deficiencies. 'It was a book' was how one described a recent deficiency letter.
'The task force will also analyze disclosure and compliance issues relating to investment advisers’ and funds’ ESG strategies'
Things an advisor should not do when it comes to advertising.
It's been a chore to lure accountants in throughout this year of the pandemic.
The GLBA shield offers advisors that fall under the CCPA no protection regarding data breaches, though. Penalties can sting.
Public company quotes 'aren’t a great comp' because 'the chaos that the pandemic has caused' means their valuations aren’t connected to the company’s fundamentals either
The OCIE request raises the specter of a long stretch of working from home.
Be aware that examiners may question your logic for placing clients in certain share classes
'If you’re subject to the law, it doesn’t really matter if you’re in or outside of California.'
If 'done incorrectly,' a compliance consultant’s work can inadvertently chart a detailed course for SEC enforcement staff to air a firm’s 'dirty laundry.'

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