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Katten Muchin Rosenman LLP

FINRA Proposes and Seeks Comment on Simplified Rules for Outside Business Activities and Private Securities Transactions

On Friday, March 14, in Regulatory Notice 25-05, the Financial Industry Regulatory Authority (FINRA) proposed a new rule to address when registered individuals engage in activities away from their member firms and when...more

Stikeman Elliott LLP

Ten LPs + 85 Investors Over Four Years = Unlicensed Trading Allegation from the OSC

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One of the grey areas for real estate development, private equity and venture capital firms (“sponsors”) that serially launch new funds is how frequently a sponsor can come to market with a new fund offering without hitting...more

Mayer Brown

US SEC Adopts Rules on Definitions of “Dealer” and “Government Securities Dealer”: Focus on Investment Advisers and Investment...

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On February 6, 2024, the Securities and Exchange Commission (SEC) adopted Rules 3a5-4 and 3a44-2 under the Securities Exchange Act of 1934 (Exchange Act), which significantly expand the definitions of “dealer” and “government...more

Jones Day

Who Needs Customers, Anyway? New SEC Rules Turn Traders Into Dealers

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The Securities and Exchange Commission (the "SEC" or "Commission") has adopted new rules that further define the phrase "part of a regular business" for purposes of determining whether a person is a "dealer" or "government...more

Wilson Sonsini Goodrich & Rosati

SEC Adopts Rule Amendments Requiring Increased Disclosure of Short Selling and Securities Lending Activities of Institutional...

On October 13, 2023, the U.S. Securities and Exchange Commission (SEC) approved final rules requiring increased disclosure of short selling activities of institutional investment managers and securities lending activities of...more

Carlton Fields

The SEC's First Regulation Best Interest Action and the Challenges of Regulating By Enforcement

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In June 2022, the U.S. Securities and Exchange Commission (SEC) filed its first complaint alleging violations of both the care and compliance obligations of Regulation Best Interest, or Reg BI. In SEC v. Western International...more

Stinson LLP

SEC Staff Posts Conflicts of Interest Guidance for Broker-Dealers and Investment Advisers

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On August 3, 2022, the Securities and Exchange Commission (SEC) staff published a Q&A-Styled Bulletin focused on conflicts of interest under the Investment Advisers Act of 1940 (Advisers Act) and Regulation Best Interest (Reg...more

Seward & Kissel LLP

SEC Files First Reg BI Action Against Broker-Dealer

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On June 15, 2022, the Securities and Exchange Commission (“SEC”) filed a complaint against California-based broker-dealer Western International Securities, Inc. (“Western”) alleging violations of Regulation Best Interest...more

Mayer Brown Free Writings + Perspectives

SEC Proposal Significantly Impacts Private Fund Advisers and Investors

On February 9, 2022, the US Securities and Exchange Commission (the “SEC”) voted to propose a suite of new rules and amendments (the “Proposal”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). If...more

Stinson LLP

SEC Proposes New Rules for Private Investment Funds

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On February 9, 2022, the SEC proposed new rules and amendments under the Investment Advisers Act of 1940 to regulate the $18-trillion private fund market. ...more

Allen Matkins

SEC: Investment Adviser May Not Say That It May Do What It Already Did

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Doug Cornelius at Compliance Building took note of an Securities and Exchange Commission order issued last Friday instituting proceedings against an investment adviser, Diastole Wealth Management, Inc., for inadequate...more

Proskauer Rose LLP

SEC’s Division of Examinations Publishes Risk Alert on Investment Adviser Principal and Cross Trading Practices

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On July 21, 2021, the Division of Examinations (“Exams”) issued a risk alert on principal and cross trading practices by investment advisers (the “Risk Alert”).  This Risk Alert supplements a prior risk alert published by...more

Goodwin

SEC Adopts New Regulatory Framework For Registered Fund Derivative Investments

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On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more

Rumberger | Kirk

Implementing Reg-BI and Preparing for Examinations: The Compliance Obligation

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With SEC Regulation Best Interest (“Reg-BI”) effective as of June 30, 2020, SEC examiners will now focus on whether firms have made a good faith effort to implement policies and procedures (“P&Ps”) that are necessary for...more

Mayer Brown Free Writings + Perspectives

Upcoming Regulation Best Interest SEC Roundtable

The Securities and Exchange Commission will hold a roundtable discussion on October 26, 2020 that will focus on Regulation Best Interest and Form CRS.  The roundtable will discuss initial observations regarding...more

Goodwin

Divided SEC Votes To Propose “Finder” Exemption From Broker Registration

Goodwin on

On October 7, 2020, the U.S. Securities and Exchange Commission (“SEC”) voted 3-2 to propose a conditional exemption (“Exemption”) to permit natural persons to engage in limited securities activities as “finders” on behalf of...more

Burr & Forman

Regulation Best Interest is Good Enough: The Second Circuit Upholds Regulation BI in XY Planning Network

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In XY Planning Network, LLC, et al. v. SEC, et al., the United States Court of Appeals for the Second Circuit rejected a challenge to Regulation Best Interest brought by an organization of investment advisers, an individual...more

Carlton Fields

Reg BI Compliance Countdown: T-Minus Six Months

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As the June 30, 2020, compliance date approaches, broker-dealers are taking steps to implement Regulation Best Interest (Reg BI), which establishes a new standard of conduct when making recommendations to retail customers of...more

Rumberger | Kirk

Minimizing Liability Under the SEC’s Reg-BI

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Litigation Risks Posed by the SEC’s Regulation Best Interest - Pete Tepley and Meredith Lees highlight litigation risks posed by the SEC’s Regulation Best Interest (Reg-BI), litigation risks that may arise from Reg-BI’s...more

Akin Gump Strauss Hauer & Feld LLP

[Podcast] AG Funds Minutes: SEC Proposes to Modernize Advertising and Cash Solicitation Rules

In this episode, Akin Gump investment management partners Barbara Niederkofler and Jason Daniel discuss the Security and Exchange Commission’s proposed modernization of the advertising and cash solicitation rules under the...more

UB Greensfelder LLP

Reg BI Continues To Tantalize And Confuse Both The Industry And The Regulators

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My young boys will sometimes chase me around the house, catch me, and yell “gotcha” as they drag me off to their pretend jail. No matter how much I plead that I’ve done nothing wrong, I always end up in jail, despite having...more

Carlton Fields

Multiple Plaintiffs Take Shot at SEC Regulation Best Interest

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The Securities and Exchange Commission’s Regulation Best Interest faces a bumpy road in the wake of recent lawsuits challenging the appropriateness and effectiveness of the rule....more

Ballard Spahr LLP

State Attorneys General Seek Injunction Against SEC’s Implementation of Regulation Best Interest

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In a very unusual lawsuit, attorneys general from seven states and the District of Columbia recently sued the SEC, and its chair, Jay Clayton, for declaratory and injunctive relief seeking to block the effectiveness of...more

Carlton Fields

Unpacking the SEC’s Regulation Best Interest Package

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On June 5, 2019, the SEC adopted a four-part regulatory package that includes: new Regulation Best Interest (Reg. BI), the related “Relationship Summary” disclosure form (Form CRS), and two interpretations of the Advisers...more

Robins Kaplan LLP

Robo-Advisors Have the Ability to Meet Fiduciary Standards, but Not All Do

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Have you ever considered investing your money with a robot? A new category of investment advisers known as robo-advisors are automated, low-cost services that provide investment advice via web or mobile platforms....more

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