Investment Adviser Representative Supervision

What this video covers

• The three non-negotiable supervisory duties: establish, maintain, and enforce written procedures
• Why "reasonably designed" means a genuine, functional system, not a perfect or psychic one
• The minimum categories under the North American Securities Administrators Association (NASAA) model rule: proxy voting, cybersecurity and physical security, client privacy, code of ethics covering material nonpublic information, and business continuity plus succession planning
• Why adopting a written policy without implementing it in day-to-day operations completely fails the supervision standard
• The annual review requirement for state-registered advisers, including designation of a chief compliance officer
• Why an adviser can be liable for an IAR's violation even with zero personal knowledge, because failure to supervise is the issue
• How adequate procedures that were actually enforced may provide a defense, while failure to establish or enforce increases vicarious liability