Nancy is a founding Member at True West. She brings over 20 years of experience in the financial industry with a concentrated focus in regulatory compliance consulting for registered investment advisory firms. She has a passion for working with clients in developing their compliance programs and assists firms with building a true culture of compliance. Nancy strives to keep a simple and straightforward approach to running an efficient compliance program.
In June 2024, the regulatory landscape for investment advisers continues to evolve with significant updates from the SEC. True West's monthly June Round-up focuses on advisory fee billing and highlights the finalized amendment to Regulation S-P.
A primary emphasis this month is on the accurate disclosure and calculation of advisory fees. We include previous SEC Risk Alerts highlighting common compliance issues, such as incorrect fee calculations and improper billing practices. Advisers are reminded to detail their fee structures clearly in the ADV disclosures and client agreements, ensuring regular reviews to maintain accuracy and proactive compliance.
The SEC also finalized an amendment to Regulation S-P, expanding the responsibilities of advisers and broker-dealers in protecting customer information. Firms must now implement robust incident response programs and notify customers promptly in case of data breaches. These changes aim to strengthen the security of customer records and ensure swift action in the event of unauthorized access.
For advisers, staying ahead of these regulatory changes involves ongoing education and efforts of maintaining good record-keeping. True West provides tools and templates to assist firms in complying with these new requirements, ensuring that advisers can continue to operate effectively and ethically in an increasingly complex regulatory environment.
Stay compliant and proactive with your policies and procedures
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