News & Analysis as of

Life Insurance Securities and Exchange Commission (SEC) Financial Services Industry

Carlton Fields

Expect Focus - Volume II, May 2025

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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

Carlton Fields

Expect Focus - Volume III, September 2023

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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...more

Carlton Fields

FOIA Competitive Injury Requirement Falls

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The Supreme Court’s June decision in Food Marketing Institute v. Argus Leader Media has made it easier for federal entities to resist certain Freedom of Information Act requests for confidential business information that the...more

Carlton Fields

New SEC Regulation Defines ‘Best Interest’ Flexibly

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Each Broker-Dealer Can Help Shape Concept Appropriately to Its Business - The SEC’s new Regulation Best Interest (Reg BI) requires broker-dealers to: - Disclose business practices in dealing with retail customers; and ...more

Carlton Fields

Use of Non-Binding SEC Staff Guidance Called Into Question

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Recent moves by the SEC could signal a shift away from the use of non-binding guidance in the form of no-action letters or other types of compliance and interpretive information that the SEC staff frequently publishes....more

Vedder Price

Investment Services Regulatory Update - December 2018

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New Rules, Proposed Rules, Guidance and Alerts – NEW RULES – SEC Adopts New Rules Permitting Covered Investment Fund Research Reports – On November 30, 2018, the SEC adopted Rule 139b under the Securities Act of...more

Carlton Fields

Expect Focus - Volume II, June 2018

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New York Pushes Mutual Fund Active Share Disclosure - New York’s Attorney General issued a report on its recent investigation of fees charged by actively managed equity mutual funds and a metric known as “Active Share.”...more

Carlton Fields

FINRA Moves Toward SEC Anti-Churning Proposal

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On April 18, the SEC voted to propose major rule changes to reconcile and clarify the standards of conduct that apply to broker-dealers and investment advisers. ...more

Carlton Fields

Expect Focus - Volume IV, December 2017

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EXPECTFOCUS is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Carlton Fields

SEC Scrutinizes Multi-Manager Arrangements

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Many mutual funds implement their investment strategies through "multi-manager" (also called "manager of manager") arrangements, particularly funds used to support variable life insurance and annuity products. Among other...more

Carlton Fields

OCIE Lessons From Cybersecurity 2 Initiative

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On August 7, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert containing observations from its Cybersecurity 2 Exam Initiative. As a follow-up to the 2014 Cybersecurity 1 initiative, the...more

Carlton Fields

Expect Focus - Volume I, March 2017

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Regulators Demand Third-Party Risk Management - While third-party risk management has been a required component of an effective enterprise risk management program for many years, the topic is receiving elevated attention...more

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