Generally, CPAs must register with the SEC as an investment
adviser if they fail a two-part test by answering "yes" to the following questions:
While large initial investments
make the biggest headlines, projects garnering inducement benefits are not restricted to gleaming new construction.
Should regulatory action or a lawsuit emerge, the IPS provides fiduciaries with "an auditable trail to prove why, how and when certain investments
were chosen," Framson says.
Unfortunately, to subordinate the sales strategy to the needs of the investment
strategy, or vice versa, is difficult for insurers in part because they have traditionally not done this and thus do not have appropriate infrastructure or support mechanisms in place.
Some economists, policymakers, and business leaders argue that creation of an international set of rules to govern international investment
would facilitate global economic efficiency, just as the GATT/WTO system spurred trade.
CPAs in at least three areas have a clear stake in ensuring accurate investment
The GLB Act itself contemplates that investments
would not be held indefinitely, and the agencies believe that it is better to establish a regulatory safe harbor that gives assurance regarding holding periods, and thereby allow FHCs to plan their investment
strategies, than for the agencies to forego providing regulatory guidance and impose decisions on holding periods for each investment
on an ad hoc basis through the supervisory process.
It's an important step forward for us,'' said Robert Boldt, senior investment
officer for CalPERS.
An integrated approach to investment
decisions includes elements of strategic manufacturing, marketing and financial planning.
Although individual members often make recommendations on investments
that they favor and have researched, the investment
committee has the authority to purchase any investment
on behalf of the group.
The fact that non-permitted investments
are made during the same period generally will not affect the eligibility of the dividend.