On June 15, 2020, SEC Chairman Jay Clayton released a public statement confirming the June 30, 2020 compliance date for Regulation Best Interest (Reg BI) and Form CRS. Reg BI establishes a new standard of conduct for...more
COVID-19 RELATED DEVELOPMENTS –
SPECIAL REGULATORY UPDATE –
New SEC Guidance on PPP Loans, Form ADV Brochure Delivery and the Custody Rule -
On April 27, 2020, the staff of the Securities and Exchange Commission (the...more
New Rules, Proposed Rules, Guidance and Alerts –
PROPOSED RULES –
Agencies Propose Volcker Rule Amendments Relating to Covered Funds –
On January 30, 2020, the Federal Reserve Board, FDIC, OCC, SEC and CFTC proposed...more
3/3/2020
/ Cybersecurity ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Investment Fund ,
Investment Funds ,
New Guidance ,
OCIE ,
Proposed Rules ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Sub-advisers ,
Volcker Rule
On January 7, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2020 examination priorities for regulated entities, including investment advisers and registered funds. The examination...more
2/27/2020
/ Anti-Money Laundering ,
Best Interest Standard ,
Broker-Dealer ,
Conflicts of Interest ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
Fiduciary Duty ,
Financial Industry Regulatory Authority (FINRA) ,
FinTech ,
Investment Adviser ,
Investment Funds ,
MSRB ,
OCIE ,
Registered Investment Advisors ,
Retail Investors ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC)
On January 9, 2020, FINRA released its 2020 Risk Monitoring and Examination Priorities Letter for its member firms. The exam priorities are organized into four categories: (1) sales practice and supervision; (2) market...more
2/27/2020
/ Best Execution ,
Compliance ,
Consolidated Audit Trail ,
Digital Assets ,
Financial Industry Regulatory Authority (FINRA) ,
Form CRS ,
Initial Public Offering (IPO) ,
Investment Adviser ,
Liquidity ,
Regulation Best Interest ,
Regulation BI ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC)
On July 11, 2019, FINRA issued Regulatory Notice 19-23 to restate and supplement its prior guidance to member firms on the circumstances under which FINRA awards credit for providing "extraordinary cooperation" during an...more
Litigation and Enforcement Actions and Initiatives –
SECTION 36(b) LITIGATION –
Court Finds for Defendant Investment Adviser in Section 36(b) -
Excessive-Fee Case –
On August 5, 2019, the U.S. District Court for the...more
9/3/2019
/ Excessive Fees ,
Financial Adviser ,
Financial Industry Regulatory Authority (FINRA) ,
Gartenberg Factors ,
Investment Adviser ,
Investment Company Act of 1940 ,
Mutual Funds ,
No-Action Letters ,
OCIE ,
Private Right of Action ,
Section 36(b) ,
Securities and Exchange Commission (SEC)
On May 23, 2019, in recognition of the one-year anniversary of the passage of the Senior Safe Act, the SEC, the North American Securities Administrators Association and FINRA issued a fact sheet to raise awareness of the act...more
7/8/2019
/ Broker-Dealer ,
Elder Issues ,
Employee Training ,
Exploitation ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Immunity ,
Investment Adviser ,
NASAA ,
Recordkeeping Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Senior Safe Act ,
Transfer Agents
Investment Services Regulatory Update –
New Rules, Proposed Rules, Guidance and Alerts –
New Rules –
SEC Adopts Rules and Interpretations Concerning the Standard of Conduct for Broker-Dealers and Investment Advisers...more
7/3/2019
/ Advisors Act ,
Best Interest Standard ,
Broker-Dealer ,
Disclosure Requirements ,
ETFs ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
New Rules ,
Proposed Rules ,
Registered Investment Companies (RICs) ,
Regulation Best Interest ,
Securities and Exchange Commission (SEC)
New Rules, Proposed Rules, Guidance and Alerts -
NEW RULES -
SEC Adopts Interim Final Rule Amending Timing Requirements for Filing Reports on Form N-PORT -
On February 27, 2019, the SEC adopted an interim final rule...more
4/3/2019
/ Custody Rule ,
Enforcement Actions ,
Excessive Fees ,
Financial Industry Regulatory Authority (FINRA) ,
Form N-PORT ,
Gun-Jumping ,
Interim Final Rules (IFR) ,
Investment Company Act of 1940 ,
Mutual Funds ,
No-Action Letters ,
OCIE ,
Proposed Rules ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Testing-the-Waters Communications
New Rules, Proposed Rules, Guidance and Alerts –
SEC STAFF GUIDANCE AND ALERTS –
OCIE Publishes Risk Alert on Compliance Issues Relating to Best Execution –
On July 11, 2018, the Office of Compliance Inspections and...more
8/21/2018
/ Best Execution ,
Broker-Dealer ,
Cryptocurrency ,
Digital Assets ,
Disclosure Requirements ,
Dismissals ,
Duty of Care ,
Enforcement Actions ,
Excessive Fees ,
Exemptions ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Company Act of 1940 ,
Investors ,
JOBS Act ,
New Guidance ,
New Rules ,
OCIE ,
Pending Legislation ,
Policies and Procedures ,
Private Right of Action ,
Proposed Rules ,
Risk Alert ,
Section 36(b) ,
Securities and Exchange Commission (SEC) ,
Virtual Currency