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Dear Reader
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Dear Reader

July 4, 2018

Anniversary Letter

The Only Constant is Change

As with basically all facets of our lives, we are constantly growing and evolving. (Of course, hopefully for the better.) Our regulatory environment is no different. Here is a recap of our financial industry transitions over the past 12 months:

ADV 1 Updates: October 2017 saw the addition of the new ADV 1 questions which impacted all RIA’s going through their annual amendments.

Cybersecurity: A couple of the more notable data breaches that came up in 2017 include Equifax and the SEC EDGAR system. Due to the sensitivity of data stolen in the Equifax breach, which included Social Security numbers and driver’s license numbers, we experienced one of the worst breaches ever.

Custody: The Standing Letters of Authorization and Inadvertent Custody guidance caused advisers to reassess how they were operationally structured to service clients’ needs. It was another opportunity to modify procedures for a surprise exam (if necessary).

Vulnerable Clients: Added attention to protecting senior investors and others from financial exploitation was the focus of the SEC, NASAA, FINRA and many states. The development of Diminished Capacity Directives and capturing of Trusted Contact information along with the implementation of delayed distribution procedures all took aim at minimizing potential abuses.

SEC’s Share Class Selection Disclosure Initiative: With a slightly modified approach than in the past, the SEC provided advisers with an opportunity to self-report violations of the federal securities laws relating to certain mutual fund share class selection issues to avoid financial penalties.

DOL Fiduciary Rule: Can’t forget about the uncertainty and turmoil around the DOL’s Fiduciary Rule. From the flurry of activity spurred by its initial passage, to the “Impartial Conduct Standards” and delayed full applicability to 7/1/2019, and now finally to its “vacation”, it’s been a rollercoaster of a ride of adjustments as firms worked to get ahead of the upcoming requirements.

SEC’s Regulation Best Interest Proposal: In place of the DOL’s version, the SEC provided their proposal for better distinguishing between the broker-dealer and investment advisory models for clients. Form CRS may become an additional disclosure requirement, but its final structure is still undetermined as public comments and industry reactions are being considered by the SEC.

If you are the Owner, CEO, President, Chief Compliance Officer - even the person in charge of marketing - you have a burden to comply with the securities laws. Our team of Professional Weightlifters has an array of compliance services and resources to lift that burden off your shoulders.

If you’re looking for cost effective ways to stay in the loop, checkout our regular publications:

  • CompliancE-Post: A free monthly e-mail service with brief postings of what's the hot industry buzz.
  • CompliancE-News: The monthly executive summary of all the news that made the news. Don't wait for the annual update — get timely details.
  • CompliancE-Alert: A value-added subscription service (which also includes the CompliancE-News) - provides timely alerts when news hits, and newly published research and forms.


If you are a do-it-yourself type person, we offer a number of compliance resources and programs:

  • RIA Fast Track Program includes compliance resources and consultations to get your operations up and running. Designed as a start-up service for new RIA firms, it is a part do-it-yourself and part "Ask the Expert." If you are creating a new RIA, contact us for details.
  • RIA Pump It Up Refresher Course includes compliance resources and consultations to get your operations in tip-top shape. Designed to lift the burden of compliance off your shoulders in an efficient and economic manner, it is a part do-it-yourself and part "Ask the Expert." If you need to dust off your compliance files, contact us for details.
  • Compliance Resources that are both educational and easily customizable to your practice are available for your use.

If you need a compliance partner providing boots on the ground support, our on-going consulting services may be the solution for you.

  • Our Professional Weightlifters are available to help you stay on top of the compliance environment and help you remember all those compliance do's and don'ts.
  • Need more time in your day? We assist you with the implementation of your compliance responsibilities.
  • Contact The Consortium to see how we can be of assistance to you: or (971) 801-1346.

— Todd Sakoda
— John Carr
— Lisanne Butterfield

The Consortium has been lifting the burden of compliance for advisors since July 4, 1989.

The Consortium
5285 Meadows Road, Ste 199
Lake Oswego, OR 97035
(971) 801-1346

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