Cipperman: I think, the best advice I can give, in terms of how you think about compliance, is that when you're a registered investment advisor, you're not operating in a free society. What I mean by that is a free society basically takes the view that you can do whatever you want so long as there's not a rule prohibiting it. That's not how regulated entities work. Regulated entities are just the opposite.
Advisors are working much more in a state society. Let's say it a different way. You can't do anything unless the rules allow it. You have to have that mindset when it comes to compliance. Before you run ahead and do something, make sure you can do it. Just because you don't know you can't do it doesn't mean you can. This is not an area where it’s better to ask for forgiveness than permission because failure to ask for permission can result in a very public and humiliating enforcement action.
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