Clarity and Understanding for the Workplace

IA Act Unwrapped

IA ACT Unwrapped™ is designed specifically to address the daily needs of Investment Adviser Compliance Officers and Securities Attorneys. This subscription-based regulatory library contains information related to the Advisers Act since its inception in 1940. No other company provides a complete, concise directory of information related to the Advisers Act spanning over 70 years! All of our information is housed within the IA Act Unwrapped™ Databases – and our information is updated daily so you will always have access to the most current information available anywhere!

Compliance Strategy Chart

A subscription to IA ACT Unwrapped™ offers you access to the following databases

Regulatory Database Advisers Act Rules Advisers Act Releases
Advisers Act No-Action Letters Enforcement Cases
Examination Tools Glossary & Definitions Search

The IA Act Unwrapped™ REGULATORY DATABASE is designed for daily use by Investment Adviser Compliance Officers and Legal Staff. The Regulatory Database offers matrix-based navigation to all current and proposed rules promulgated under the Advisers Act.

As shown above, in the Regulatory Database every Rule under the Advisers Act is setup with tabs of the following information:

In addition to the matrix-format of the Regulatory Database, IA Act UnwrappedTM contains the following Databases with specific resources.

The IA Act Unwrapped™ ADVISERS ACT RULES Database reflects the current-to-the-day version of the Rules, with historical links to adopting, amending and interpretative Releases. Any pending proposed amendments to the Rules are clearly marked.

The IA ACT Unwrapped™ RELEASES Database contains every Release promulgated under the Investment Advisers Act – from Release IA-1 issued in 1940 through all current Releases, shown in both full and summary format, categorized by type. No other resource offers access to a summary and full text of every Release every issued. This database of almost 4,000 Releases is maintained current-to-the day. These Releases are all full-text searchable.

The IA ACT Unwrapped™ ADVISERS ACT Database contains the complete text of the Investment Advisers Act of 1940, including all recent amendments as mandated under The Dodd-Frank Wall Street Reform and Consumer Protection Act.  It is interesting to note that the SEC’s website does not contain the content of the Advisers Act, but rather links to the Act at another outside source.

The extensive IA ACT Unwrapped™ NO-ACTION LETTER Database contains recent and significant letters issued by the SEC's Division of Investment Management for requests for relief under the Advisers Act. In this Database, you may sort the letters by name, date, or by reference to the rule under which relief was sought.

The IA ACT Unwrapped™ ENFORCEMENT CASE Database contains litigation releases, initial decisions and cases that played a significant role in the history of investment adviser compliance, such as Capital Gains, Arlene Hughes, Steadman, Goldstein, etc.

The IA ACT Unwrapped™ EXAMINATION TOOLS Database contains sample SEC Document Request Lists, Examination Brochures, Sample Sweep Letters, Speeches, Guidance and information from the Division of Investment Management, OCIE, the SEC’s National Exam Program (NEP) and the SEC's Compliance Outreach Program. Our database also lists current Examination Focus areas.

Our IA ACT Unwrapped™ GLOSSARY & DEFINITIONS Database provides wide-ranging information on a multitude of topics relevant to the investment adviser world, and beyond. The Database shows where a term is used, e.g. in Form ADV or Form PF, and also links to significant Cases and Releases that give further information on the importance of the term in specific context.

IA ACT Unwrapped™ contains a very sophisticated SEARCH capability. The Release Database, No-Action Letter Database and Enforcement Database are all full-text (not just “keyword”) searchable. Search by any word and find what you need – instantly!

Search

Unwrap the mystery of compliance under the Advisers Act. A Subscription to IA Act UnwrappedTM gives you access to all the information you need – any time – any day.

Headline News

SEC Charges IA and Former COO with Defrauding Client
Read more...

Engaging on Non-DVP Custodial Practices and Digital Assets
Read more...

SEC Share Class Initiative Returning More Than $125 Million to Investors
79 IAs Who Self-Reported Agree to Compensate Investors Promptly, Ensure Adequate Fee Disclosures
Read more...

BB&T to Return Over $5 Million to Retail Investors and Pay Penalty Relating to Directed Brokerage Arrangements
Read more...

Benincasa Named First Chief Risk Officer
Strengthens SEC’s Risk Management & Cybersecurity Efforts
Read more...

Updates

Brightline Solutions updates IA Act UnwrappedTM on a daily basis. Recent updates are listed below. Click HERE for a more detailed summary of the information.

IA-5203 In the Matter of Richard G. Cody

ICI Mutual Funds and Investment Management Conference
Keynote Address by Dalia Blass, Director, Division of Investment Management
Added to the IA Act UnwrappedTM Examination Tools Database/2019 Information

ICI Mutual Funds and Investment Management Conference
Keynote Remarks by SEC Commissioner Elad L. Roisman
Added to the IA Act UnwrappedTM Examination Tools Database/2019 Information

IA-5202 In the Matter of Grant Gardner Rogers

IA-5201 In the Matter of Talimco, LLC

IA-5200 In the Matter of Craig Arsenault

LR-24424 SEC v. Dale M. Walker

Edmunds Private Capital, LLC
Amended Application for Exemptive Order under Advisers Act Section 202(a)(11) (definition of "investment adviser") (March 12, 2019)
Added to IA Act UnwrappedTM Regulatory Database Family Office Rule 202(a)(11)(G)-1 No-Action/Exemptive Order Request Tab

Engaging on Non-DVP Custodial Practices and Digital Assets 
Division of Investment Management Letter to K. Barr/Investment Adviser Association (Mar. 12, 2019)
To inform future steps and in light of growth in the variety and complexity of the types of securities and other assets commonly utilized by registered investment advisers that settle on a Non-DVP (delivery-versus-payment) basis, the staff, through the Division’s Analytics Office, has launched an initiative to gather information on Non-DVP practices. The Division also requests comment to further inform consideration of how characteristics of digital assets impact the application of the Custody Rule.
Added to the IA Act UnwrappedTM Examination Tools Database/2019 Information and to the Plain English Description Tab under Regulatory Database Rule 206(4)-2

Release Nos. IA-5123 through IA-5199
SEC Share Class Initiative Returning More Than $125 Million to Investors
79 IAs Who Self-Reported Agree to Compensate Investors Promptly, Ensure Adequate Fee Disclosures

IA-5122 In the Matter of John Gregory Schmidt

IA-5121 In the Matter of Ascension Asset Management, LLC and Grenville M. Gooder, Jr.

LR-24418 SEC v. Goldsky Asset Management, LLC and Kenneth Grace

IA-5120 In the Matter of Lewis Dean McBride

IA-5119 In the Matter of BB&T Securities, LLC, as successor-in-interest to Valley Forge Asset Management, LLC

IA-5118 In the Matter of Raymond K. Montoya

IA-5117 In the Matter of Michael Scronic

LR-24408 SEC v. James S. Polese, et al

IA-5116 In the Matter of John Thomas Capital Management Group LLC and George R. Jarkesy Jr.
OPINION - Order Regarding Further Proceedings

IA-5115 In the Matter of Vishal Savla

IA-5114 In the Matter of Brian Hirsch

IA-5113 In the Matter of Bennett Group Financial Services, LLC and Dawn J. Bennett

IA-5112 In the Matter of Hector A. May

IA-5111 Adjustments to Civil Monetary Penalty Amounts

IA-5110 Ajenifuja Investments, LLC; Order Cancelling Registration
Registrant has not met the conditions of the Internet adviser exemption
Added to the IA Act UnwrappedTM Releases Database and linked to the Risks and Plain English Description Tabs of Regulatory Database Rule 203A-2: Exemptions from prohibition on Commission registration.

IA-5109 In the Matter of Timothy S. Batchelor

IA-5108 In the Matter of Ronald W. Nichter

LR-24390 SEC v. Thomas Conrad, Jr. et al.

IA-5107 In the Matter of Andrew B. Scherr

IA-5106 In the Matter of Kenneth Grace

LR-24388 SEC v. Alexander C. Burns, et al.

IA-5105 In the Matter of John L. Gaithright, Jr.

IA-5104 In the Matter of John Austin Gibson, Jr.

IA-5103 In re: Pending Administrative Proceedings
Appropriations to the Commission have been restored - the SEC lifts the stay.

LR-24386 SEC v. Daniel H. Glick, et al.

LR-24384 SEC v. Howard B. Present
Added to the IA Act UnwrappedTM Enforcement Case Database and linked to Regulatory Database Rule 206(4)-8 Risks/Significant Enfocement Cases Tab

IA-5102 In the Matter of Apollo Management, L.P.
Added to the IA Act UnwrappedTM Releases Database and to the No-Action/Exemptive Requests Tab under Regulatory Database Rule 206(4)-5

LR-24383 SEC  v. Joseph A. Meyer, Jr. and Statim Holdings, Inc.

IA-5101 In re: Pending Administrative Proceedings
Lapse in appropriations forces stays in all pending administrative proceedings

IA-5100 In the Matter of Katz, Sapper & Miller, LLP, and Scott C. Price, CPA
Added to the IA Act UnwrappedTM Releases Database and to Risks/Significant Cases under Regulatory Database Custody Rule 206(4)-2

IA-5099 In the Matter of Stephen T. Carbonella

IA-5098 In the Matter of John Sherman Jumper

IA-5097 In the Matter of Walter John Dubiel

IA-5096 In the Matter of Lightyear Capital LLC

IA-5095 In the Matter of Alexander C. Burns

IA-5094 In the Matter of Warren D. Nadel

IA-5093 In the Matter of Timbervest, LLC

IA-5092 In the Matter of Patric Ken Baccam

IA-5091 In the Matter of Mohammed Riad and Kevin Timothy Swanson

IA-5090 In the Matter of Thoroughbred Financial Services, LLC, Thomas Jenkins Parker, and Lawrence Randall “Randy” Hartley

IA-5089 In the Matter of Paul Edward "Ed" Lloyd, Jr. CPA

IA-5088 In the Matter of Black Diamond Asset Management, LLC and Robert Wilson

IA-5085 In the Matter of Sterling Global Strategies, LLC
Added to the IA Act UnwrappedTM Releases Database and linked to the term "back-testing" in the Glossary & Definitions Database