On April 30, 2019, US Court of Appeals for the DC Circuit decided an important case involving the disclosure obligations of investment advisers. The case decided that an adviser’s disclosure that it “may” have a conflict of...more
5/16/2019
/ Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Broker-Dealer ,
Conflicts of Interest ,
Disclosure Requirements ,
Financial Services Industry ,
Form ADV ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Mutual Funds ,
Negligence ,
Revenue Sharing ,
Securities and Exchange Commission (SEC)
On April 16, the SEC's Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert outlining issues related to compliance with Regulation S-P that it identified in its inspections of SEC-registered...more
4/26/2019
/ Broker-Dealer ,
Customer Information ,
Cybersecurity ,
Data Protection ,
Investment Adviser ,
OCIE ,
Opt-Outs ,
Personally Identifiable Information ,
Policies and Procedures ,
Regulation S-P ,
Risk Alert ,
Safeguards Rule ,
Securities and Exchange Commission (SEC)
On February 7, the US Securities and Exchange Commission's (SEC) Office of Compliance Inspections and Examinations (OCIE) published its examination priorities for 2018 (the "2018 Priorities Report"). Given that OCIE's...more
On November 29, the US Department of Labor (DOL) finalized its 18-month extension of the transition period under the Best Interest Contract Exemption (the "BIC Exemption"). As described in Katten's earlier advisory,...more
On August 9, the US Department of Labor (DOL) announced in a court filing that it has proposed an 18-month extension of the full implementation of the Best Interest Contract Exemption (the "BIC Exemption") under the ERISA...more
The DOL's "fiduciary advice rule" (the "Rule") will take effect on June 9, 2017. The DOL has published FAQs on the implementation of the Rule applicable to the period between June 9th and December 31st (the "Transition...more
On August 25, the Securities and Exchange Commission (SEC) adopted amendments to Form ADV and to certain rules promulgated under the Investment Adviser Act of 1940, as amended (the "Advisers Act"). These amendments will be...more
On November 16, 2015, the Securities and Exchange Commission (SEC) sued an investment adviser, Virtus Investment Advisers, Inc., who had hired another adviser, F Squared Investments, Inc., to sub-advise certain mutual funds...more
On September 22, 2015, the Securities and Exchange Commission (SEC) filed a settled administrative proceeding[1] alleging that a registered investment adviser failed to adopt cybersecurity procedures in violation of an SEC...more