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OCIE Finds Supervision Failures at Multiple-Branch Office Investment Advisers

On November 9, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced the results of its examination of nearly 40 SEC-registered investment advisers that operate multiple branch offices (the...more

Ready or Not, Prepare to Start Answering Questions About Reg BI Compliance

On June 5, 2019, the SEC adopted Regulation Best Interest (“Reg BI”), which requires broker-dealers and associated persons to make recommendations regarding securities transactions (or investments involving securities) that...more

North American Securities Administrators Association (NASAA) Releases Model Cybersecurity Rule

On May 21, the North American Securities Administrators Association (NASAA)—an organization comprised of 67 securities regulators within the United States (all fifty states as well as districts and territories), Canada, and...more

SEC OCIE Highlights Potential Deficiencies in Firm Privacy Policies

On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting Regulation S-P compliance deficiencies and issues it found in recent examinations of broker-dealers and...more

Recent New Jersey Rule Proposal Progresses State Efforts to Impose Fiduciary Duties on Brokers

On April 15, the New Jersey Bureau of Securities (the “Bureau”) issued a rule proposal to establish a uniform fiduciary duty standard applicable to investment advisers, brokers-dealers and their registered representatives and...more

The Broker Protocol’s Demise — Imminent or Greatly Exaggerated?

For 14 years, the Protocol for Broker Recruiting has allowed financial advisors to leave their employer firms and take specific client information with them without fear of a retaliatory lawsuit. Recently, however, the...more

Fifth Circuit Vacates Controversial DOL Fiduciary Rule

On March 15, the U.S. Court of Appeals for the Fifth Circuit issued a decision vacating the Department of Labor’s Fiduciary Rule, the controversial measure requiring brokers and other financial professionals to adopt a “best...more

FINRA Proposes Transformative Rule on Outside Business Activities

On Feb. 26, the Financial Industry Regulatory Authority issued Regulatory Notice 18-08 seeking comment on a proposed new rule to address outside business activities of registered persons. The proposal, a result of FINRA’s...more

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