The U.S. Securities and Exchange Commission has adopted amendments to the increasingly utilized “internet adviser exemption.” The exemption, originally adopted in 2002, has fostered the utilization of digital platforms for...more
The Financial Regulatory Authority (FINRA) recently identified the “initial themes” observed in a targeted examination of retail communications by member firms with respect to crypto assets. The headline grabbing statistic:...more
It should come as no surprise to financial industry participants that the first Risk Alert published by the SEC’s Division of Examinations (the “Division”) in 2023 relates to Regulation Best Interest (“Reg BI”). The Risk...more
No later than November 4, 2022, investment advisers must have implemented measures necessary to comply with the amended Advisers Act Rule 206(4)-1(i.e., the “Marketing Rule”). Recently, the SEC’s Division of Examinations...more