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!

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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

OCIE Issues Risk Alert Highlighting Compliance Issues Related to Reg S-P
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SEC Names Deputy Chief Counsels of the Division of Investment Management
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New SEC Campaign Educates Investors on Where and How to Get Answers
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COO Fraudulently Caused Advisory Firm to Overbill Clients
Inflated salary by hundreds of thousands of dollars per year
Read more...

IA Charged with Stealing Millions from Private Fund
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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.

LR-24455 SEC v. Motty Mizrahi et al.

IA-5224 In the Matter of Matthew R. Rossi and SJL Capital, LLC

IA & BD Compliance Issues Related to Regulation S-P - Privacy Notices and Safeguard Policies 
OCIE Risk Alert (April 16, 2019) 
Added to the IA Act UnwrappedTM Examination Tools Database/2019 Information

IA-5223 In the Matter of Stanley S. Bae

SECret Garden 
Commissioner Hester M. Peirce at SEC Speaks 2019
Important Issues for Investors in 2019 
Rick Fleming, Investor Advocate at SEC Speaks 2019
Remarks have been added to the IA Act UnwrappedTM Examination Tools Database/2019 Information

IA-5222 In the Matter of Karen Bruton and Hope Advisors, LLC

LR-24449 SEC v. Arif M. Naqvi and Abraaj Investment Management Limited

IA-5221 In the Matter of Martin R. Stancik

LR-24447 SEC v. Gonzalo Ortiz

IA-5220 In the Matter of Ascension Asset Management, LLC and Grenville M. Gooder, Jr.
Protective Order for personally identifiable information

Encouraging Smaller Entrants to Our Capital Markets
Remarks by Commissioner Elad L. Roisman at the 2019 SEC Speaks Conference
Added to the IA Act UnwrappedTM Examination Tools Database - 2019 Information

Management’s Discussion and Analysis of the SEC
SEC Chairman Jay Clayton's Remarks at the 2019 SEC Speaks Conference 
Added to the IA Act UnwrappedTM Examination Tools Database/2019 Information

IA-5219 Notice of Intention to Cancel IA Registration of NeoCap, LLC

LR-24444 SEC v. Scott Newsholme

IA-5218 In the Matter of Alonzo R. Cahoon

IA-5217 In the Matter of Omar Zaki

LR-24435 SEC v. Motty Mizrahi and MBIG Company

LR-24434 SEC v. Richard T. Diver

IA-5216 In the Matter of Gregory M. Bercowy

IA-5215 In the Matter of Dennis Gibb and Sweetwater Investments, Inc.

IA-5214 In the Matter of Ascension Asset Management LLC and Grenville E. Gooder, Jr.

IA-5213 Generation Investment Management US LLP and Generation Investment Management LLP
Added to the IA Act UnwrappedTM Releases Database and to the No-Action/Exemptive Order Tab under Regulatory Database Rule 206(4)-5, Pay to Play

IA-5212 In the Matter of Oscar Francis

LR-24432 SEC v. Direct Lending Investments, LLC

IA-5211 In the Matter of Neil Maxwell

IA-5210 In the Matter of Charles G. Stivers

IA-5209 In the Matter of Karl R. Dierman

IA-5208 In the Matter of Kevin D. Wanner

IA-5207 Regulatory Flexibility Agenda

Wells Fargo Securities LLC
No-Action Letter
Added to the IA Act UnwrappedTM No-Action Letter Database and to the No-Action Tab under Regulatory Database Rule 206(4)-3

PLI Investment Management Institute 2019
Remarks by Paul Cellupica, Deputy Director & Chief Counsel, Division of Investment Management
Added to the IA Act UnwrappedTM Examination Tools Database/2019 Information

IA-5206 FAST Act Modernization and Simplification of Regulation S-K
Final Rule Release

IA-5205 In the Matter of Roy Dekel

IA-5204 In the Matter of Harding Advisory LLC and Wing F. Chau - OPINION

LR-24430 SEC v. Carol Ann Pedersen

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