- Form ADV Disclosure: Top deficiencies were inconsistencies between the information contained on Form ADV Parts 1 and 2
- Failure to maintain and safeguard client records
- Missing client agreements, altered documentation and signing blank documents
- Lax supervision, especially over remote offices
- Advertising misstatements involving websites, client correspondence, business cards and the misuse of “Registered Investment Adviser” and “RIA”
State securities regulators, such as the California Department of Corporations, will likely use this information to focus their exams on areas that have proven to need improvement. Accordingly, investment advisers should rigorously review their compliance policies and procedures to increase the likelihood that they are in full compliance with the areas identified in the NASAA examination report.For additional information please contact the JLG Team at (619) 298-2880.