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FinCEN and SEC propose Customer Identification Program requirements for investment advisers

Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

SEC takes on AI use by broker-dealers and investment advisers - Expansive coverage of types of technology and investor interaction...

In a Legal Alert issued before the SEC open meeting, we posed five questions that our Investment Services team would be looking out for as part of this meeting. We now have answers to some of these questions....more

SEC takes on AI use by investment advisers and broker-dealers - Some big questions about where we are headed

The US Securities and Exchange Commission (SEC) is holding an open meeting this Wednesday to consider whether to propose new and amended rules under the Securities Exchange Act of 1934 and the Investment Advisers Act of 1940...more

Considerations as Regulation Best Interest and Form CRS approach June 30th compliance date

The compliance date for two rules adopted by the US Securities and Exchange Commission (SEC) last year, Regulation Best Interest (Reg BI) and the Form CRS Relationship Summary (Form CRS) is rapidly approaching for...more

The emerging patchwork of fiduciary investment advice regulation – Putting the pieces together (update)

As anticipated, 2020 has seen a number of fiduciary and best interest advice regulations advance at both the federal and state levels. Firms subject to these regulations face challenges in dealing with rules that impose a...more

Videocast: Asset management regulation in 2020 videocast series – SEC’s OCIE exam priorities [Video]

The SEC’s Office of Compliance Inspections and Examinations recently announced its 2020 examination priorities, which focus on key areas of risk for the financial services and asset management industries. This Bottom Line...more

A leg up for ETFs - SEC issues final ETF rule

On September 26, 2019, the US Securities and Exchange Commission (SEC) announced that it has adopted the eagerly awaited new rule 6c-11 (the Rule) under the Investment Company Act of 1940 (the 1940 Act) that allows most...more

The emerging patchwork of fiduciary investment advice regulation – Putting the pieces together (update)

As anticipated, this year has seen a number of fiduciary and best interest investment advice regulations advance at both the federal and state levels. Firms subject to these regulations will face challenges in dealing with...more

Form CRS: Implementation Considerations

What happened? On June 5, in a three-to-one vote, the US Securities and Exchange Commission (SEC) adopted a comprehensive package of rulemakings and interpretations governing the standard of conduct applicable to...more

SEC approves investment advice standard of conduct rules

Today, in a 3-1 vote, the US Securities and Exchange Commission (SEC) adopted a comprehensive package of rulemakings and interpretations governing the standard of conduct applicable to broker-dealers providing retail...more

Counting down to June 5

Admittedly, it is not one of those “Do you remember where you were when it happened?” moments (for those old enough to remember, think November 16, 1981, when Luke and Laura married), but for the broker-dealer and investment...more

The emerging patchwork of fiduciary investment advice regulation – Putting the pieces together (update)

By all accounts, 2019 will see a number of fiduciary and best interest investment advice regulations advance at both the federal and state levels. Firms subject to these regulations will face challenges in dealing with rules...more

The emerging patchwork of fiduciary investment advice regulation – Putting the pieces together

By all accounts, 2019 will see the advancement of a number of fiduciary and best interest investment advice regulations at both the federal and state levels. Firms subject to these regulations will face challenges in dealing...more

SEC Charges Investment Adviser with Failure to Adopt Required Cybersecurity Policies Prior to Breach

On September 22, the Securities and Exchange Commission (SEC) announced that it had entered into a settlement order with R.T. Jones Capital Equities Management, Inc. (R.T. Jones), a St. Louis-based SEC registered investment...more

SEC Publishes 2014 Examination Priorities for Investment Advisers

On January 9, 2014, the U.S. Securities and Exchange Commission (SEC) published its 2014 examination priorities letter (“SEC Letter”) for its National Examination Program (NEP). The NEP covers all markets and entities...more

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