Implementing the New Form CRS: Don’t Overlook the Details

Feb 14, 2020 7:45:00 AM

In June 2019, the SEC announced Regulation Best Interest (Reg BI), the long-awaited standard that was meant to be the industry’s answer to the now-vacated Department of Labor Fiduciary Rule.  Though Reg BI impacts broker-dealers most heavily, it does have some implications for RIAs as well. In addition, Reg BI is part of a rulemaking package that adopted other new rules, including one that require...

Overhaul Your Privacy Policy, Part 2: Elements of a good privacy policy

Jan 24, 2020 1:00:00 PM

Like most legal documents, privacy policies are fairly bland , and, let’s be honest, few people read them. But the recent enactment of the California Consumer Protection Act (“CCPA”) has Joot fielding privacy policy questions from clients and service providers alike. In our previous post - Is it time to overhaul your privacy policy and notice? - we discussed whether your firm must comply with the ...

SEC Exam Priorities 2020

Jan 17, 2020 11:15:00 AM

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2020 examination priorities on January 7, 2020. OCIE releases this list on an annual basis in order to provide the industry with insights into areas it may focus on thorough the examination process. All the priorities listed on the 2020 list were also on the 2019 list, with some new additions. Which makes us wonder ...

Is it time to overhaul your privacy policy and notice?

Jan 10, 2020 10:45:00 AM

California recently passed amendments to the California Consumer Protection Act (“CCPA”), which took effect on January 1, 2020! Under the CCPA, investment advisers that are located in or have clients in California may need to update their privacy policy and notices to comply with the new law. For a deeper discussion of the new law, I recommend Morgan Lewis’ LawFlash updates from July and September...

Joot Interview Series - Episode 8

Dec 17, 2019 11:15:00 AM

In this final part of our third Interview (Part 1, Part 2). Bo Howell continues his discussion with Charles Black about the DO's and DON'Ts of SEC Exams.  Charles brings over 17 years of experience in the financial services industry to provide great tips and insight on what to do when the SEC calls. Topics of this three-part interview include: How to approach an SEC exam. Responding to SEC exam re...

Diversity & Inclusion: Steps Forward in the Asset Management Industry

Dec 12, 2019 11:40:00 AM

Diversity and inclusion have a positive impact on all businesses and the asset management industry is no exception.  Companies with a diverse and inclusive staff are able to better identify with and understand a wider range of clientele, which then enables them to be more creative and innovative in the ways they help those clients. Welcoming diverse perspectives also provides a way to engage assoc...

Joot Interview Series - Episode 7

Dec 10, 2019 11:30:00 AM

This is Part 2 of our third Interview (Part 1). Bo Howell continues his discussion with the newest member of Joot, Charles Black about SEC Exams.  Charles brings over 17 years of experience in the financial services industry to provide great tips and insight on what to do when the SEC calls. Topics of this three-part interview include: How to approach an SEC exam. Responding to SEC exam requests. ...

Rise of the Machines, Part 3: How big data is changing more than just portfolio management

Dec 5, 2019 11:30:00 AM

Introduction  By Bo Howell  As we race towards the end of 2019, I can’t help but think about where we’ve been over the past year and where we are headed. This series of articles was written with both perspectives in mind. As a user and developer of technology, I’m very interested in the interplay between machines and people. We live in a society where computers are part of nearly all aspects of ou...

Joot Interview Series - Episode 6

Dec 3, 2019 2:00:20 PM

In our third Interview, Bo Howell speaks with the newest member of Joot, Charles Black, to discuss SEC Exams.  Charles brings over 17 years of experience in the financial services industry to provide great tips and insight on what to do when the SEC calls. Topics of this three-part interview include: How to approach an SEC exam. Responding to SEC exam requests. (DOs and DON'Ts) SEC exam interview ...

Rise of the Machines, Part 2: Changing Portfolio Management

Nov 21, 2019 12:30:00 PM

Introduction By John Simmons In Part 1: Rise of the Machines: How increased Automation in financial services impacts society, we discussed some of the benefits and dangers of increased automation with asset managers. In Part 2, we will dive deeper into the key adaptations of an investment advisor. Specifically, we look at how automation is changing portfolio management and what future portfolio ma...

Joot Interview Series - Episode 5

Nov 19, 2019 11:30:00 AM

Welcome back to our second Joot interview.  We’re excited to continue delivering helpful content and thought leadership to you. This week’s edition is Part 2 of 2 (about 15 minutes).  You can listen to Part 1 here. In this episode, Bo Howell, CEO of Joot, speaks with Mark Baltimore , Co-CEO of Global Rhino.  They discuss trends in distribution and what asset managers should expect over the next fi...

Joot Interview Series - Episode 4

Nov 12, 2019 12:00:00 PM

Welcome to our second Joot interview.  We’re excited to continue delivering helpful content and thought leadership to you. This week’s edition is Part 1 of 2 (about 15 minutes). In it Bo Howell, CEO of Joot, speaks with Mark Baltimore , Co-CEO of Global Rhino , about why distribution is so hard to get right, why distribution is not just sales, and the steps that asset managers should take when dev...

Rise of the machines, Part 1: How increased automation in financial services impacts society

Nov 7, 2019 1:00:00 PM

Introduction By Bo J. Howell Recently, I read some articles in The Economist newspaper that talked about the increasing use of computers in asset management. While the topic is not new to those of us in the industry, I thought of our recent intern, John Simmons, who is graduating from Xavier University next month and is focused on becoming a portfolio manager. I wondered what skills does John need...

Joot Expands its Compliance Team

Nov 4, 2019 10:43:00 AM

We are excited to announce the newest addition to the Joot team: Charles Black! Charles brings over 17 years of experience in the asset management industry, including roles in compliance, fund accounting, and fund administration. Charles has served as a compliance officer for both investment advisers and investment companies. Most recently, he served as the Chief Compliance Officer for a few mutua...

Testing 1-2-3

Oct 25, 2019 1:00:00 PM

Having the right policies and procedures in place is a key component of an effective compliance program but it’s only part of the equation. Maintaining consistent adherence to these policies and procedures is equally important. One of the things our customers have asked for is a more efficient and automated way to do this. That’s why we are excited to announce the official release of our Testing M...

10 Tips to Avoid Pay-to-Play Restrictions

Oct 17, 2019 11:15:00 AM

I recently attended a panel discussion designed to provide tips to stay on the right side of pay-to-play requirements. Asset managers that manage investments of public entities (primarily state and local municipalities and their agencies) need to avoid the strict liability standards that are triggered by crossing the line.  Of course, the panel started with an overview of SEC Rule 206(4)-5 and sim...

Compliance Testing Programs - Part 2: The bottom-up approach to building your compliance program.

Oct 10, 2019 11:30:00 AM

In part two of our panel recap where we discussed compliance testing programs for small and medium-size firms, we zero in on the foundation. (If you missed part one: a top-down approach, you can find it here.) Flipping the top-down approach that we discussed las week, we began to look at critical components of the business and how to review and test your procedures effectively. The following are s...

Joot Interview Series - Episode 3

Oct 8, 2019 11:15:00 AM

Welcome back to the conclusion of our interview between Bo Howell and Cynthia Custer.   (You can hear Part One or Part Two here.) In Part 3 (about 10 minutes), we dive deeper into issues related to share class selection and talk about: Best execution factors that go beyond price.  Third-party money managers: Who’s responsible for best execution? How Joot digitizes compliance for RIAs.  Why the fut...

Compliance Testing Programs for Small & Medium Firms - Part 1

Oct 3, 2019 11:19:00 AM

PART 1 - The Top Down Approach I had the good fortune to participate in a compliance panel with esteemed adviser CCOs in which we shared our lessons learned about building and maintaining effective compliance testing programs from top to bottom.  To avoid drinking from a fire hose, I will cover the nitty-gritty details in a two-part blog, one starting from the top and the other building up from th...

Joot Interview Series - Episode 2

Oct 1, 2019 11:15:00 AM

Welcome back to part 2 of our interview between Bo Howell and Cynthia Custer.   (if you missed part one, listen here.) In Part 2 (about 15 minutes), which we’ll post next week, we talk about: Why Cynthia and her firm, Advisory Compliance Solutions, joined the Joot family.  how technology can make SEC compliance easier, improve compliance oversight, and reduce operational costs. Recent trends in SE...

A  Fresh Look at Vendor Due Diligence

Sep 26, 2019 12:44:00 PM

By Nick Horvath Vendor due diligence, an oldie… but a goodie.  Vendor due diligence has been a risk mitigation technique since the words Caveat Emptor were first spoken.  But what about today? How much emphasis should your firm place on vendor due diligence? Why should you care? Let us count the ways. Risk identification is increasingly difficult in our global, digital economy Most small firms don...

Joot Interview Series - Episode 1.

Sep 24, 2019 11:30:00 AM

Hello, Joot community! Welcome to our first Joot interview.  We’re excited to continue delivering helpful content and thought leadership to you. We had fun recording the interview, and once we've done a few more this may become a podcast.  We hope that you’ll find it helpful.  This week’s edition is Part 1 of 3 (about 15 minutes). In it Bo Howell, CEO of Joot, speaks with Cynthia Custer, Director ...

Joot Expands its Compliance Team and Service Offerings

Sep 19, 2019 12:50:00 PM

We are excited to announce the newest addition to the Joot team: John Ramirez! According to Bo Howell, CEO of Joot, the firm has been growing steadily and it is focused on building the right team to deliver both innovative technology and exceptional services. “I am excited to have John join our team. He’s an experienced entrepreneur, talented attorney, and seasoned compliance officer,” says Howell...

Q&A: Client Relationship Summary (Form CRS)

Sep 5, 2019 11:45:00 AM

Last week, Joot published an article on Regulation Best Interest and Form CRS (Customer or Client Relationship Summary). We heard from many of our readers about the article and we’re glad it was helpful. Some of you had great questions about the application of Form CRS and the definition of a “retail investor”. Below are our responses to your questions. Keep ‘em coming! Definition of Retail Invest...

SEC: Regulation Best Interest

Aug 29, 2019 11:15:00 AM

As many of you know, on June 5, 2019, the SEC passed Regulation Best Interest (Regulation BI) and related rules and interpretations that were intended to enhance investor protection and clarify the difference between broker-dealers (BDs) and registered investment advisers (RIAs). The rule and two final interpretations were over 1,300 pages long, ugh. When I think about reading that many pages of b...

Joot discusses FinTech with the Institute for Innovation Development - Part 2

Aug 15, 2019 10:25:00 AM

Note. If you didn’t get a chance to read our FinTech-partnership article that was published by the Institute for Innovation Development (IID), we recommend you start there and then continue on.  In last week’s blog post, we gave you some more color on our discussion with the IID on how financial advisers should partner with FinTech. We discussed how we work with clients to identify their real comp...

Joot discusses FinTech with the Institute of Innovation Development - Part 1

Aug 8, 2019 3:00:00 PM

Joot CEO Bo Howell recently teamed up with the Institute for Innovation Development (IID) to discuss how financial advisers should approach FinTech. The article was published on Nasdaq.com and other sites on August 5, 2019. You can read the complete article here. (Do us a favor, if you like the article, please share it on social media. If you don’t like it, please pretend like you do and share it ...

Advisory Compliance Solutions Merges with Joot

Aug 1, 2019 3:00:00 PM

Joot grows its team and area of expertise! CINCINNATI, OHIO – August 1, 2019 - Joot, a leading provider of compliance technology and services to small and middle-sized investment advisers, today announced its merger of Advisory Compliance Solutions, LLC (ACS). As part of the merger, Cynthia Lower Custer, Managing Member of ACS, will become Treasurer and Director of Compliance Services at Joot.  “W...

Making Things Beta

Jul 25, 2019 4:30:00 PM

There is still some time (but not too much time) to get yourself into the beta program for Joot's NEW Policies and Testing Manager!  Policies and Testing Manager brings it all together by integrating with our SEC Filing Manager, Compliance Calendar, and Document Manager to form a comprehensive solution that helps RIAs manage their compliance processes and documentation. Identify the types of polic...

You Beta Believe It!

Jul 15, 2019 9:53:00 AM

It’s summertime, and it's hot, very hot! But here at Joot, we’ve been working on some pretty cool things, and today, we’re announcing the launch of our beta program for the latest addition to our CCO Tech compliance platform: Policies and Testing Manager! (We’re considering a cooler name for this great tool, so if you have suggestions, leave a comment below. Personally, I wanted to call it Mjöllni...