BEST PRACTICES: FOLLOW THE LEADER DUE DILIGENCE PRIMER: REGISTERED INVESTMENT ADVISERS AND BROKER-DEALERS

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1 BEST PRACTICES: FOLLOW THE LEADER DUE DILIGENCE PRIMER: REGISTERED INVESTMENT ADVISERS Even though an investment adviser or a broker-dealer may be registered at the state or federal level, active registration status by no means indicates they have earned a regulatory seal of approval. This presentation explores a number of due diligence tools available to investors, investigators, and fraud examiners to help uncover prior disciplinary history and conflicts of interest at these registered entities. JAMES T. CONVERSANO, CFE, CFA Principal Berkeley Research Group Washington, DC For the past 20 years, Jim has provided expert regulatory, financial, investment management, compliance, and forensic investigation services to attorneys and clients in a number of major civil and criminal litigation matters involving securities litigation, alleged breach of fiduciary duties, regulatory inspections and examinations, insider trading investigations, complex financial fraud investigations, and compliance and risk assessments. Jim provided expert analysis for the SEC Office of Inspector General s 457-page report, SEC Office of Inspector General s Investigation of the Failure of the SEC to Uncover Bernard Madoff s Ponzi Scheme, and provided recommendations in the related report, Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC. Disclaimer: The opinions expressed in this presentation are those of the individual author and do not represent the opinions of Berkeley Research Group or its other employees and affiliates. The information provided in this presentation is not intended to and does not render legal, accounting, tax, or other professional advice or services, and no client relationship is established with Berkeley Research Group by making any information available in this publication, or from you transmitting an or other message to us. None of the information contained herein should be used as a substitute for consultation with competent advisors. Association of Certified Fraud Examiners, Certified Fraud Examiner, CFE, ACFE, and the ACFE Logo are trademarks owned by the Association of Certified Fraud Examiners, Inc. The contents of this paper may not be transmitted, re-published, modified, reproduced, distributed, copied, or sold without the prior consent of the author. 2012

2 Due Diligence Primer: Registered Investment Advisers and Broker-Dealers Even though an investment adviser or a broker-dealer may be registered at the state or federal level, active registration status by no means indicates they have earned a regulatory seal of approval. Still, active registration status of such entities does provide investors and industry professionals access to a significant amount of resources that are useful when conducting due diligence. Yet, many people are unaware that such information is available and readily accessible online. This presentation explores a number of tools available to investors, industry professionals, and investigators that will uncover prior disciplinary history and conflicts of interest, and should be considered necessary steps when conducting due diligence of registered broker-dealers and investment advisers. Registration Forms for Broker-Dealers The provisions that require all securities brokers to be registered with the Securities and Exchange Commission are covered under Section 15 of the Securities Exchange Act of In addition to oversight by the SEC, brokerdealers are also regulated by the Financial Industry Regulatory Authority (FINRA), which is a self-regulatory organization and the largest independent regulator for all securities firms doing business in the United States. The SEC has oversight of FINRA. SEC Form BD is the Uniform Application for Broker- Dealer Registration. Broker-dealers must file this form to register with the SEC, the self-regulatory organizations, and jurisdictions through the Central Registration Depository system (discussed below), operated by FINRA. For individuals conducting due diligence, Form BD contains useful information, including the legal status of

3 the organization, identification of direct and indirect ownership, activities of affiliates, regulatory history, relevant business activities, and a list of all key executives (i.e., chief executive officer, chief financial officer, chief operations officer, chief legal officer, chief compliance officer, director). Form BD provides the foundation for establishing who the firm is and what it does. Following is a link to Form BD and its instructions: Central Registration Depository (CRD) The Central Registration Depository is a computerized database used by regulators that contains information about most brokers, their representatives, and their employers. The CRD contains information about the brokers educational backgrounds, where they worked before their current jobs, whether they are properly licensed in your state, and if they have had disciplinary problems with regulators or received serious complaints from investors. The CRD is operated by FINRA and is the source for much of the information used to generate the FINRA BrokerCheck reports that are made available to the general public. FINRA BrokerCheck FINRA established the BrokerCheck program in 1988 to provide investors and the general public with information on the professional background, business practices, and conduct of FINRA member firms and their associated persons. On FINRA s website, it emphatically states, [BrokerCheck] should be the first resource investors turn to when choosing whether to do business or continue to do business with a particular broker or brokerage firm. Information for BrokerCheck is collected on uniform registration forms submitted to the CRD for broker-dealers

4 and registered representatives. FINRA Rule 8312, FINRA BrokerCheck Disclosure, provides the regulatory framework for the information required to be made available in BrokerCheck. BrokerCheck is free and does not require registration. That alone makes it attractive for conducting due diligence. FINRA provides the following detailed breakdown of information available related to brokers and firms: 1 Information available pertaining to registered representatives includes: Current employers A 10-year employment history Other businesses the individual engages in All approved licenses and registrations Qualification exams passed Criminal felony charges and convictions Investment-related misdemeanor charges and convictions Disciplinary actions and investigations by regulators Investment-related civil judicial actions and proceedings Most consumer-initiated complaints, arbitration proceedings, and civil litigations Unsatisfied judgments, liens, bankruptcy proceedings Employment terminations that follow allegations of certain misconduct or failure to supervise Any final sanction (such as bars, suspensions, and fines) imposed by FINRA, the SEC, or other federal or state regulatory agencies Information available pertaining to brokerage firms includes: 1. estmentprofessional/p

5 Administrative information, including address, legal status, types of business engaged in, and direct and indirect owner/officer information A 10-year history of all felony charges and convictions, as well as investment-related misdemeanor charges and convictions Disciplinary actions and proceedings initiated by regulators A 10-year history of investment-related civil judicial actions and proceedings Bankruptcy proceedings Unsatisfied judgments or liens Summary information on arbitration awards For former FINRA-registered firms, the date that the firm ceased doing business and, when appropriate, details regarding funds owed customers or other firms BrokerCheck reports do not provide all the information available in the CRD. The SEC suggests that you ask your state securities regulator or the Financial Industry Regulatory Authority (FINRA) to provide you with information from that CRD that might not be available in BrokerCheck. In fact, the SEC states on its website, Because your state securities regulator may provide more comprehensive information from the CRD than FINRA, especially when it comes to investor complaints, you may want to check with your state securities regulator first. Following is a link to the main BrokerCheck search page: Conducting a search is relatively easy. From the main BrokerCheck search page, you select Start Search, where you will then be asked to agree to the FINRA website s terms and conditions

6 Terms and conditions page: After agreeing to the terms and conditions, you can search for a broker or brokerage firm:

7 Note: As you proceed with your search, you will also be asked to enter randomly generated authentication information, which will be displayed on the next screen of your search. Once you have selected a firm to view, BrokerCheck provides a summary page displaying the following: Firm Name CRD# SEC# Address Information Report Summary Firm Profile Firm History Firm Operations Disclosure of Arbitration Awards, Disciplinary, Financial, and Regulatory Events BrokerCheck Quick Tips: On the summary display page for a particular firm or individual, look for the following questions highlighted in blue (with applicable answer included) toward the bottom half of your screen: Is this brokerage firm currently suspended with any regulator? (Yes/No) Are there events disclosed about this firm? (Yes/No)

8 In the upper right-hand corner, look for the solid blue icon titled GET DETAILED REPORT. Clicking on this icon will generate a comprehensive report in.pdf format that includes all disclosure information (including disciplinary and regulatory events). For individual representatives, in particular, this information is critical to understand the disciplinary history of a registered representative of a brokerage firm. For searches of larger broker-dealers, the amount of disciplinary information related to the entre firm can be quite voluminous, so think twice before printing the results. Recent and Proposed Changes to BrokerCheck BrokerCheck has seen many changes over the years. Notable changes in recent years include the addition of hyperlinks in individual broker reports that provide information related to any disciplinary actions taken against them. In addition, records about brokers who leave the brokerage industry (and may take on other financial advisory roles) are now available going back ten years instead of two. Another relatively recent rule change includes a formal procedure for challenging errors. Brokers will be able to submit a written dispute notice and supporting documents to FINRA using an online form. FINRA will then add a notation to the broker s report indicating that the disclosure is under dispute. If FINRA determines an entry is inaccurate, it will modify or eliminate it. Still, more changes to BrokerCheck are expected soon. In January 2011, SEC staff released a study and recommendations on improving investor access to investment adviser and broker-dealer registration information, as required by Section 919B of the Dodd- Frank Wall Street Reform and Consumer Protection Act

9 (Dodd-Frank Act). In the study, SEC staff makes the following three near-term recommendations to improve investor access to registration information through BrokerCheck: Unify search returns for BrokerCheck and the Investment Adviser Public Disclosure (IAPD) databases. Add the ability to search BrokerCheck by zip code or other indicator of location. Add educational content to BrokerCheck, including links and definitions of terms that may be unfamiliar to investors. The Dodd-Frank Act mandates that these recommendations be implemented within 18 months after completion of the study, and FINRA will put them into effect before the July 2012 deadline. One area that leaves much room for improvement is the lack of detailed information regarding terminations. Although terminations appear frequently, it seems as though no one ever gets fired in the securities industry, based on the limited disclosures provided when a departure from a firm is reported. Typically, no useful detail is provided regarding such departures. FINRA Arbitration Awards Online Database The FINRA Arbitration Awards Online Database is a relatively new resource available to investors and investigators. Similar to BrokerCheck, it s free and doesn t require registration. FINRA s Arbitration Awards database enables users to perform Web-based searches for FINRA arbitration awards and historical arbitration awards for NASD, 2 the New York Stock Exchange, the American 2. FINRA is the successor to the National Association of Securities Dealers, Inc., (NASD) and was formed in July 2007 by a consolidation

10 Stock Exchange, the Philadelphia Stock Exchange, and the Municipal Securities Rulemaking Board. Users may search for awards by case number, document text, date of award (by date range), or a combination of document text and date of award. Awards can be viewed online, printed, or downloaded as text-searchable PDF files. On rare occasions, a FINRA arbitration award is vacated by a court. When FINRA receives a copy of the order vacating an award, it attaches the order to the respective award in the Arbitration Awards Online database. FINRA began this practice in March In February 2012, FINRA started posting all court orders relating to arbitration awards (including court orders that deny a motion to vacate). FINRA posts court orders relating to arbitration awards only when FINRA receives copies of the orders. For this reason, FINRA encourages parties to research independently whether a court has vacated, confirmed, or modified a prospective arbitrator s past awards. Parties are further cautioned that FINRA s Arbitration Awards Online database might not reflect whether a party has appealed an order or the outcome of any such appeal. Following is a link to the FINRA Arbitration Awards Online Database: finraawardsonline.finra.org Broker-Dealer Audit Reports In addition to the significant disciplinary disclosures that may be available through BrokerCheck and the FINRA Arbitration Awards Online Database (if applicable), of NASD and the enforcement arm of the New York Stock Exchange, NYSE Regulation, Inc

11 additional useful information might be available in the audit reports of broker-dealers. Pursuant to Exchange Act Rule 17a-5, broker-dealer audit reports must be periodically submitted to the Registrations Branch in Washington, DC. In addition, Rule 17a-5(d)(6) also requires the brokerdealer to file the annual audit report at the regional or district office of the commission for the region or district in which the broker-dealer has its principal place of business and at the principal office of the designated examining authority for the broker-dealer, and to provide copies to all self-regulatory organizations of which the broker-dealer is a member. The Annual Audited Report, Form X-17A-5, Part III, Facing Page must be completed and attached to the front of each copy of the audited financial statements. Form X-17A-5 is commonly referred to as the FOCUS Report (Financial and Operational Combined Uniform Single Report). These annual reports provide information regarding the net worth, revenue, and profitability of the firm, which is often useful to forensic accountants and investigators. These reports are typically available online via the SEC s EDGAR database, but if not, can typically be requested through a Freedom of Information Act (FOIA) request to the SEC. It is now fairly common knowledge that a number of Bernard L. Madoff Investment Securities LLC s annual and quarterly reports filed with the SEC contained contradictory and inaccurate information that should have raised a number of red flags, had they been carefully reviewed and scrutinized. PCAOB Registration of Broker-Dealer Auditors The Dodd-Frank Act provided the PCAOB with new oversight authority over the audits of broker-dealers registered with the SEC. Financial statements of brokerdealers filed with the SEC for fiscal years ending after

12 December 31, 2008, must be certified by a PCAOB- registered public accounting firm. Dodd-Frank expanded the PCAOB s oversight of the audits of brokers and dealers to now include inspections, enforcement, and standard setting authority. The PCAOB may provide useful information regarding the registration status of an accounting firm that audits a broker-dealer of interest. The following is a link to PCAOB s website that lists all currently registered accounting firms by name and location: pcaobus.org/registration/firms/pages/default.aspx Registration Form for Investment Advisers Investment advisers are generally regulated by the SEC pursuant to the Investment Advisers Act of 1940 or state securities authorities pursuant to applicable state regulations. The SEC typically regulates investment advisers that have assets under management in excess of $100 million, 3 and investment advisers that do not meet this threshold generally are regulated by the states. 4 The SEC registers investment adviser firms, but does not separately register individual representatives of investment adviser firms. In contrast, the states register investment adviser firms, as well as individual investment adviser representatives. Both the SEC and the states may require certain investment advisers to hedge funds and other private funds that are not required to be registered (Exempt 3. Title IV of the Dodd-Frank Act includes amendments to the Investment Advisers Act of 1940 that effectively reallocated primary responsibility for oversight of investment advisers that have between $25 million and $100 million of assets under management from the SEC to the states. 4. SEC-registered investment advisers must also file, with each state in which they are doing business, a copy of any and all filings made with the SEC strictly for notice purposes. Hence, these are called Notice Filings

13 Reporting Advisers) to instead file certain disclosure reports with them. The most critical disclosure form related to registered investment advisers that is available to potential investors and industry professionals is SEC Form ADV. Form ADV is the uniform registration form used by investment advisers to register with both the SEC and state securities authorities. Some advisers that are exempt from registration (Exempt Reporting Advisers) also complete a portion of the questions in Form ADV for purposes of reporting to the SEC and/or the states. All investment advisers must periodically update the information in their filings. Form ADV consists of two portions, Part 1 and Part 2. Form ADV Part 1 requires information about the investment adviser s business, ownership, clients, employees, business practices, affiliations, and any disciplinary events of the adviser or its employees. Part 1 filings made by registered investment advisers are available on the SEC s Investment Adviser Public Disclosure website. Form ADV Part 2 requires investment advisers to prepare a narrative brochure written in plain English that contain information such as the types of advisory services offered, the adviser s fee schedule, disciplinary information, conflicts of interest, and the educational and business background of management and key advisory personnel of the adviser. The ADV Part 2 brochure is the primary disclosure document that investment advisers provide to their clients. As such, Form ADV Part 2 should be required reading for anyone conducting due diligence of a registered investment adviser, if available. Amazingly, Part 2 is not required to be filed electronically and made available online. When filed, the brochures are

14 available to the public on the SEC s Investment Adviser Public Disclosure website. However, registered investment advisers are required to deliver annually to clients a summary of material changes to the brochure, and either deliver a complete updated brochure or offer to provide the client with the updated brochure. In addition, an investment adviser must deliver to clients a brochure supplement that provides information about the specific employees, acting on behalf of the investment adviser, who actually provides the investment advice to the client. The brochure supplement also includes contact information for the person s supervisor in case the client has a concern about the person. The brochure supplement must be delivered either before or at the time that the employee begins to provide investment advice to a client. An updated supplement must be delivered to clients when there is new disclosure of a disciplinary event, or a material change to disciplinary information that has already been disclosed. So, what if you are not a client and the Form ADV Part 2 is not available online? Unless you have subpoena or regulatory authority, you may need to contact the registered investor adviser directly and request a copy. More than likely, most firms will readily provide you with a current copy. Requests for past versions dating back one or more years, however, may ruffle the feathers of in-house legal counsel, as they are typically quite sensitive to potential lawsuits that may be related to disclosure issues (a focus of numerous ongoing securities litigation cases). Form ADV-E In December 2009, the SEC approved amendments to the custody rule under the Investment Advisers Act of 1940 and related forms. The amendments, among other things, require certain registered investment advisers that have custody of client funds or securities to undergo an annual

15 surprise examination by an independent public accountant to verify client funds and securities. Form ADV-E is used as a cover page for a certificate of accounting of securities and funds, of which the investment adviser has custody. Form ADV-E contains both information about the adviser and the surprise exam conducted. The surprise exam report is created by an independent public accountant after a surprise inspection of the adviser. The Form ADV-E filing and the surprise examination report or statement filed by the accountant will be made public information, and will be available to the public on Investment Adviser Registration Depository (IARD) The Investment Adviser Registration Depository is an electronic filing system for investment advisers sponsored by the SEC and North American Securities Administrators Association, with FINRA serving as the developer and operator of the system. The IARD system collects and maintains the registration and disclosure information for investment advisers and their associated persons. The IARD system supports electronic filing of Forms ADV, centralized fee and form processing, regulatory review, the annual registration renewal process, and public disclosure of investment adviser information. FINRA does not have regulatory authority over investment advisers; however, it was chosen to develop, operate, and maintain the system because of its regulatory business and technical expertise. The IARD provides regulators with the ability to monitor and process investment adviser information via a single, centralized system. SEC Investment Adviser Public Disclosure (IAPD) Pursuant to the Investment Advisers Act of 1940, the SEC established and maintains the Investment Adviser Public

16 Disclosure, a readily accessible electronic process to respond to public inquiries about investment advisers and their disciplinary information. The IAPD provides information about both SEC-registered and state-registered investment adviser firms, certain investment adviser firms that are exempt from registration with the SEC or states, and state-registered investment adviser representatives. 5 The IAPD also contains information about investment advisers that were registered or filed reports in the previous ten years but are no longer registered or reporting advisers. Use of the IAPD website is free and does not require registration. As explained on the IAPD website, the IAPD allows you to do the following: 6 Search for an investment adviser firm. View the adviser s current Form ADV. Check the adviser s registration or reporting status. Search for an investment adviser representative. View the representative s professional background and conduct. Check the representative s registration status. Link to a state regulator s website. Link to the FINRA BrokerCheck website for information about broker-dealers and stockbrokers. However, the IAPD does not contain information about advisers that: Are exempt from registration, but are not required to file reports as Exempt Reporting Advisers Have filed unapproved applications for registration with the SEC or a state 5. Surprisingly, until 2010, the IAPD only included information on investment adviser firms. 6. ent/iapdmain/siteexplanation.aspx

17 Following is a link to the Investment Adviser Search page: h.aspx And below is a screen shot of the Investment Adviser Search page: You are given the option of searching for an Investment Adviser Representative (IAR) or an Investment Adviser Firm. For instance, below is a screenshot of the page displayed when Investment Adviser Firm is selected:

18 The IAPD allows you to search by individual or firm name, firm Investment Adviser Registration Depository (IARD) number, or individual Central Registration Depository (CRD) registration number. 7 IAPD Quick Tips: Once you are viewing the disclosures within the IAPD for a particular registered investment adviser, you will see a navigation panel on the left of the screen with hyperlinks to various sections of the disclosure pages. You can quickly confirm whether the ADV Part 2 brochure is available by scrolling to the section titled Part 2 Brochure. If it is available, there will be a 7. The CRD is a database that contains the registration records of broker-dealers and securities representatives. Information in the CRD is obtained through forms that brokers, brokerage firms, and regulators complete as part of the securities industry registration and licensing process

19 hyperlink available that will take you directly to the brochure. Interested in disciplinary history? From the left navigation panel, scroll down and click the hyperlink for DRP (Disclosure Reporting Page). To print all disclosures: From the left navigation panel, scroll down and click the hyperlink for View All, which will create a.pdf of all disclosures. Note: This will not include the ADV Part II brochure, if available. You will still need to manually click on that hyperlink (if available) to open that document. Searches of registered investment adviser firms in the IAPD should be supplemented with searches of each registered investment adviser representative that works at the firm (if known or suspected). Neither the SEC nor the state securities authorities have explicitly approved the information filed on Form ADV, and will not guarantee its accuracy. The IAPD displays an investment adviser s most recent Form ADV. The website is updated as investment advisers amend their Forms ADV. Don t Forget the State Regulators One of the most frustrating aspects of conducting due diligence on broker-dealers and investment advisers is that all of the information typically needed is not centralized with one regulator or on one website. And because these firms and individuals may also be registered at the state level, it is often necessary to request information from state regulators where the firm or individual is registered. The North American Securities Administrators Association provides contact information for each state securities regulator

20 The following is a link to North American Securities Administrators Association s list of contact information for state securities regulators: Requesting information from the state securities regulators typically does not involve an automated, online process or database similar to the IAPD or BrokerCheck. Rather, it typically involves making inquiries through phone calls and . Keep in mind that state regulators also utilize the CRD and are able to provide useful information upon request, and such information may not always be accessible through BrokerCheck. Further, states are well positioned to ensure investor protection proactively because they conduct background checks of investment adviser representatives. Such background checks serve a dual function: to provide investors with assurances that their investment adviser representatives are free from violations of the law, and that potential problems with bad actors do not have the opportunity to reach fruition. The SEC and FINRA cannot perform this vital function because neither the commission nor FINRA register investment adviser representatives

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