On Oct. 18, 2019, the Securities and Exchange Commission (SEC) Division of Investment Management staff published Frequently Asked Questions Regarding Disclosure of Certain Financial Conflicts Related to Investment Adviser...more
On June 5, 2019, the SEC adopted Regulation Best Interest (“Reg BI”), which requires broker-dealers and associated persons to make recommendations regarding securities transactions (or investments involving securities) that...more
On May 21, the North American Securities Administrators Association (NASAA)—an organization comprised of 67 securities regulators within the United States (all fifty states as well as districts and territories), Canada, and...more
On April 30, the U.S. Circuit Court of Appeals for the District of Columbia Circuit vacated a Securities and Exchange Commission order imposing sanctions. The court held that an investment advisory firm and its owners did not...more
On April 30, the U.S. Circuit Court of Appeals for the District of Columbia Circuit vacated a Securities and Exchange Commission order imposing sanctions. The court held that an investment advisory firm and its owners did not...more
Enforcement actions sanctioning firms and, in a few cases, individuals for failing to investigate and report suspicious activity have been significantly on the rise. SEC, FinCEN, FINRA, and others have been active in this...more
On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting Regulation S-P compliance deficiencies and issues it found in recent examinations of broker-dealers and...more
4/25/2019
/ Broker-Dealer ,
Customer Information ,
Cybersecurity ,
Data Protection ,
Data Security ,
Investment Adviser ,
OCIE ,
Personally Identifiable Information ,
Policies and Procedures ,
Privacy Policy ,
Regulation S-P ,
Risk Alert ,
Securities and Exchange Commission (SEC)
It was never a question of if, but rather, when would the Securities and Exchange Commission launch its first charges against robo-advisors and what those charges would be. Following the then SEC Chairperson’s, Mary Jo White,...more
For 14 years, the Protocol for Broker Recruiting has allowed financial advisors to leave their employer firms and take specific client information with them without fear of a retaliatory lawsuit. Recently, however, the...more
While the securities industry focused on parsing the Securities and Exchange Commission’s recently proposed best-interest standard and speculating about the ultimate fate of the Department of Labor’s vacated fiduciary rule,...more
The Financial Industry Regulatory Authority and the states traditionally have handled the bulk of retail brokerage investigations, such as the suitability of a retail broker’s investment recommendations or alleged excessive...more
On February 18, 2016, Financial Industry Regulatory Authority (FINRA) announced that it had issued a targeted exam letter, or sweep, to firms seeking information about how firms establish, communicate and implement cultural...more
As we discussed yesterday, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (OCIE) released its examination priorities for 2016 on January 11 (the “Examination Priorities”)....more