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Expect Focus - Volume II, May 2025

Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more

Amendments to N-PORT May Be OUT-Ported New SEC Reporting Requirements Already Under Challenge

Gary Gensler’s tenure as SEC chair can be remembered for an impressive number of rule proposals, many of which encountered vehement industry opposition or were challenged in court, struck down, or stayed....more

Expect Focus - Volume IlI, September 2024

Gone With the Wind? Closed-End Funds Risk Extinction - Shares of SEC-registered closed-end funds (CEFs) have long held significant potential advantages for some investors. For example, unlike shares of mutual funds...more

FINRA and SEC Float Concerns Over Social Media Finfluencers

Social media marketing is an important form of advertising in our digital world, particularly with a target audience of younger investors. This has caught the eye of FINRA and the SEC....more

Regulators Hit Jackpot: Off-Channel Communications

Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about problematic record-keeping practices involving the use of...more

A Spring Into Chaos: Massachusetts Adopts Fiduciary Rule

The standard of conduct for broker-dealers is quickly becoming a crazy quilt of securities regulation. Apparently unsatisfied with the standard established under SEC Regulation Best Interest (Reg BI), some state securities...more

Reg BI Compliance Countdown: T-Minus Six Months

As the June 30, 2020, compliance date approaches, broker-dealers are taking steps to implement Regulation Best Interest (Reg BI), which establishes a new standard of conduct when making recommendations to retail customers of...more

DC Circuit: Willful Means Intentional Under the Advisers Act – Negligent Conduct Cannot Be Willful Conduct

In Robare Group v. SEC, the court clarified the meaning of “willfully” under Section 207 of the Investment Advisers Act of 1940. A willful omission requires that a person “subjectively intended to omit material information.”...more

Unpacking the SEC’s Regulation Best Interest Package

On June 5, 2019, the SEC adopted a four-part regulatory package that includes: new Regulation Best Interest (Reg. BI), the related “Relationship Summary” disclosure form (Form CRS), and two interpretations of the Advisers...more

Regulatory Musical Chairs for Money

The SEC and FINRA continue to play musical chairs with staff resources allocated to examinations of investment advisers and broker-dealers. According to SEC Chair Mary Jo White’s remarks at an April 16 SEC Compliance...more

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