More On Legal & Compliancefrom The Advisor's Professional Library
- Client Communication and Miscommunication RIA policies and procedures must specify what type of communications should be retained. The safest course of action is for RIAs to retain all communicationsto clients, from clients, and about client accounts. To comply with fiduciary obligations, communications must be thorough and not mislead.
- Client Commission Practices and Soft Dollars RIAs should always evaluate whether the products and services they receive from broker-dealers are appropriate. The SEC suggested that an RIAs failure to stay within the scope of the Section 28(e) safe harbor may violate the advisors fiduciary duty to clients, so RIAs must evaluate their soft dollar relationships on a regular basis to ensure they are disclosed properly and that they do not negatively impact the best execution of clients transactions.
The SEC announced Tuesday that David Grim has been appointed deputy director of its Division of Investment Management.
Grim has worked in the division for 17 years, most recently as assistant chief counsel in its Office of Chief Counsel, and has received several awards for his legal and managerial work, according to the SEC.
In early December, one of former SEC Chairwoman Mary Schapiro’s senior advisors, Jennifer McHugh, was named senior advisor to Norm Champ, the director of the SEC’s Division of Investment Management.
Champ said in a statement that Grim brings “intellectual curiosity and extensive management experience, and is committed to our program of making the division an organization that grows through continuous improvement.”
Grim joined the SEC in September 1995 as a staff attorney in the division’s Office of Investment Company Regulation. In January 1998, he moved to the division’s Office of Chief Counsel, where he has served in a variety of positions, including since September 2007 as assistant chief counsel. Grim received the SEC Capital Markets Award in 2005, the SEC Supervisory Excellence Award in 2007 and the SEC Law and Policy Award in 2011.
“I am honored to have the opportunity to work with Norm and my dedicated colleagues in the division to carry out our vitally important mission on behalf of investors,” Grim said.
Grim graduated cum laude with a degree in political science from Duke University and received his law degree from George Washington University, where he was managing editor of the George Washington Journal of International Law and Economics.