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
As just about everyone who operates in the mutual fund, closed-end fund or exchange-traded fund (ETF) industries knows, the Investment Company Act of 1940, as amended (the “1940 Act”), requires certain key registered...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
Last February, the Division of Enforcement of the SEC (the “Division”) launched the Share Class Selection Disclosure Initiative (the “Initiative”). The Initiative enabled registered investment advisers (“RIAs”) to self-report...more
On September 20th, the SEC released a proposed rule amending Rule 17a-5 of the Securities Exchange Act of 1934, as amended (“Exchange Act”).[1] Under Rule 17a-5(d)(1)(i)(C) of the Exchange Act, broker-dealers registered with...more