Common exam issues

  • Outdated, inaccurate or incomplete Form ADV
  • Annual written offer of advisers disclosure statements (HAR §16-39-439) needs to be evidenced and maintained
  • Books and records deficiencies
  • Missing authorizations for trades in non-discretionary accounts
  • Failure to obtain and updated client information (financial data, objectives, etc.)
  • Annual financial statements not filed timely with the commissioner (HAR §16-39-437)