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 its full 70 years! A subscription to IA ACT Unwrapped is offered on two levels.

IA ACT Unwrapped Level 1 is designed for daily use by Investment Adviser Compliance Officers and Legal Staff. Level 1 offers matrix-based navigation to all current and proposed rules promulgated under the Advisers Act, with links to: adopting and amending rule releases; pertinent no-action letters; a description of the requirements of each rule written in plain-English format; as well as a discussion of associated risks; disclosure and recordkeeping requirements; considerations when testing your firm's compliance under each particular rule; and definitions of associated terms. The complete text of the Advisers Act is also offered in Level 1. More information…

If you have any questions, please contact Brightline Solutions by emailing us at Info@BrightlineSolutions.com or by calling 860-672-4433. To purchase IA ACT Unwrapped Level 1, please click here.

“Simplicity is the ultimate sophistication.” ~Leonardo da Vinci

IA ACT Unwrapped Level 2 is designed to address the more complex needs of Securities Attorneys and the Compliance Staff of larger firms. In addition to all of the information provided in the Level 1 matrix, Level 2 offers several extensive relational databases of information, including 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. This database of over 3,100 Releases is maintained current-to-the day.

Level 2 also offers access to an extensive No-action Letter Database of all recent and significant letters issued by the SEC's Division of Investment Management. Sort the letters by name, date, or by reference to the rule under which relief was sought.

Our Level 2 Enforcement 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 Level 2 Release Database, No-Action Letter Database and Enforcement Database are all full-text searchable.

The Level 2 Examination Database contains sample SEC Document Request Lists, Examination Brochures, Sample Sweep Letters, and information from OCIE and the SEC's CCOutreach program.

Our Advisers Act Database offers access to the current version of the Act, including all recent amendments mandated under The Dodd-Frank Wall Street Reform and Consumer Protection Act.

Our extensive Glossary & Definitions Database provides wide-ranging information on a multitude of topics relevant to the investment adviser world, and beyond.

If you have any questions, please contact Brightline Solutions by emailing us at Info@BrightlineSolutions.com or by calling 860-672-4433. To purchase IA ACT Unwrapped Level 2, please click here.

Headline News

Lapse in Appropriations Forces Stays in All Pending Administrative Proceedings
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In the Midst of Gov't Shutdown SEC Brings Charges in EDGAR Hacking Case
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Custody Violations – Auditors Failed to Have Relevant Knowledge, Training & Experience
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OCIE Status during Government Shutdown
Limited staff on hand only for emergency situations
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Division of Investment Management Unavailable during Government Shutdown
Limited Staff Available to Answer Questions Relating to Fee Calculations for Filings
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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-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

IA-5084 In the Matter of PPS Advisors, Inc., and Lawrence Nicholas Passaretti

IA-5083 In the Matter of American Portfolios Advisors, Inc.

Two Robo-Advisers Charged with False Disclosures:
IA-5086 In the Matter of Wealthfront Advisers, LLC
IA-5087 In the Matter of Hedgeable, Inc.

Added to the IA Act UnwrappedTM Releases Database and linked to the term "robo-advisers" in the Glossary & Definitions Database
Also refer to the following related information which has been reposted in the IA Act UnwrappedTM Examination Tools Database under 2018 Information: Robo-Advisers IM Guidance Update 2017-02 (originally published 02/23/17); Investor Bulletin: Robo-Advisers SEC Investor.gov (originally published 02/23/17)

OCIE 2019 Examination Priorities
Added to the IA Act UnwrappedTM Examination Tools Database/2018 Information

Madison Capital Funding LLC - No-Action
No-Action Letter under Rule 206(4)-2

Added to the IA Act UnwrappedTM No-Action Letter Database and to Regulatory Database Custody Rule 206(4)-2 No-Action Tab

IA-5082 In the Matter of James S. Polese

IA-5081 In the Matter of Mark J. Moskowitz

IA-5080 In the Matter of Walter F. Grenda, Jr.

IA-5079 In the Matter of NB Alternatives Advisers LLC

IA-5078 In the Matter of Central States Capital Markets, LLC

IA-5077 In the Matter of Ancora Advisors, LLC
Added to the IA Act UnwrappedTM Releases Database and Regulatory Database Rule 206(4)-5 Risks/Significant Cases Tab

Observations from Investment Adviser Examinations Relating to Electronic Messaging
National Exam Program/OCIE Risk Alert reminds advisers of their obligations when their personnel use electronic messaging and to help advisers improve their systems, policies, and procedures by sharing the staff’s observations from these examinations.
Added to the IA Act UnwrappedTM Examination Tools Database/2018 Information and to Regulatory Database Rules 204-2 & 206(4)-7

IA-5076 In the Matter of Chris D. Rosenthal
Added to the IA Act UnwrappedTM Releases Database; the terms "flipping" and "parking" added to the Glossary & Definitions Database and linked to the Release

IA-5075 In the Matter of UBS Financial Services Inc.

IA-5074 In the Matter of Yucaipa Master Manager, LLC

IA-5073 In the Matter of Richard W. Kessler

IA-5072 In the Matter of Landaas & Company and Robert W. Landaas

LR-24367 SEC v. Michael B. Rothenberg

IA-5071 In the Matter of John C. Maccoll

IA-5070 In the Matter of Fifth Street Management, LLC

IA-5069 In the Matter of Ronald Wayne Nabors

IA-5068 Apollo Management, L.P.
Added to the IA Act UnwrappedTM Releases Database and to the No-Action/Exemptive Request Tab under Regulatory Database Rule 206(4)-5

IA-5067 List of Rules to be Reviewed Pursuant to the Regulatory Flexibility Act

2019 Investment Adviser Renewal Bulletin
Added to the IA Act UnwrappedTM Regulatory Database Rule 204-1 Plain English Description and Disclosure & Record Tabs

IA-5066 In the Matter of Mark Hotton

LR-24359 SEC v. Kimberly Pine Kitts

IA-5065 In the Matter of Retirement Capital Strategies, Inc.

LR-24356 SEC v. James S. Polese, et al

Costumes, Candy, and Compliance
SEC Commissioner Hester M. Peirce - Remarks at the NSCP 2018 National Membership Conference
Added to the IA Act UnwrappedTM Examination Tools Database/2018 Information and to the Risks Tab under Regulatory Database Rule 206(4)-7