The U.S. Securities and Exchange Commission (the “Commission”) recently entered into four consent orders (collectively, the “Orders” and each, an “Order”) with registered investment advisers (“RIAs” and each, an “RIA”) that...more
In recent weeks, we have observed significant new developments in securities regulation related to two enforcement actions by the U.S. Securities and Exchange Commission (the “Commission”) and an unexpected (and, to our...more
Putting Teeth on Reg BI (to take a bite out of complex products sales), Protecting Seniors (from romance scams, affinity frauds, and rogue POAs), Scrutinizing Bank-Based Reps, DBAs, and Remote Supervision, and the beginning...more
Each year, the SEC’s Division of Examinations (f.k.a. OCIE) (the “Division”) releases its priorities for the upcoming year, providing SEC registrants with a helpful tool to assist in managing, reviewing, and updating their...more
4/12/2021
/ Anti-Money Laundering ,
Broker-Dealer ,
Environmental Social & Governance (ESG) ,
ETFs ,
Fiduciary Duty ,
FinCEN ,
FinTech ,
Form CRS ,
Investment Adviser ,
OCIE ,
Registered Investment Advisors ,
Regulation Best Interest ,
REIT ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC)
The political melee surrounding Regulation Best Interest (“Reg BI”) escalated yesterday with the filing of a lawsuit against the SEC by several state attorneys general (the “State Plaintiffs”). In their complaint, the State...more
Regulations regarding privacy, cybersecurity and the use of technology seem to be in constant flux. Compliance consultants and vendors do their best to stay on top of them, but ultimately neither are regulated by the SEC,...more
5/30/2019
/ Broker-Dealer ,
Cloud Storage ,
Cybersecurity ,
Data Protection ,
Data Security ,
Data Storage Providers ,
Investment Adviser ,
OCIE ,
Policies and Procedures ,
Popular ,
Vendors
On Monday, April 15, the New Jersey Bureau of Securities (“NJBS”) released its long-awaited proposed fiduciary rule (the “Proposed Rule”) for broker-dealers (“BDs”) and investment advisers (“IAs”).1 Key points from the Rule...more
New Jersey released its long-awaited proposed fiduciary rule (the “Fiduciary Rule”) for broker-dealers and investment advisers. The 60-day comment period for the Fiduciary Rule began today, and will end on June 14, 2019....more
Last week FINRA issued guidance (Regulatory Notice 19-10) with respect to communications with customers about registered representatives (“RRs”) who have left a broker-dealer (the “Notice”).
With increased frequency, RRs...more
Last April, the SEC released proposed rules related to the standard of care that broker-dealers (“BDs”) owe their customers and issued proposed guidance related to the standard of care that investment advisers (“IAs”) owe...more
As we prepare for a new year of regulatory initiates and actions, we believe it is important to take inventory of the most significant regulatory events from the past year. True to its word, the SEC focused on reducing...more
1/3/2019
/ Broker-Dealer ,
Cryptocurrency ,
Cybersecurity ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Form ADV ,
Initial Coin Offering (ICOs) ,
Investment Adviser ,
Investors ,
Liquidity ,
OCIE ,
Opportunity Zones ,
Proposed Regulation ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act