News & Analysis as of

Regulation BI Form CRS

WilmerHale

The SEC Division of Examinations' Fiscal Year 2025 Priorities

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On October 21, 2024, the Securities and Exchange Commission Division of Examinations published its examination priorities for fiscal year 2025.1 In this alert, we offer ten observations for broker-dealers. Our observations...more

Goodwin

SEC EXAMS Division 2025 Priorities Signal Continued Scrutiny of Broker-Dealers

Goodwin on

The SEC Division of Examinations (EXAMS) recently published its list of priorities for 2025, providing a roadmap for broker-dealers and other registrants to better understand where examination teams will focus their efforts...more

Orrick, Herrington & Sutcliffe LLP

FINRA charges member firm with Regulation Best Interest violations

On August 5, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) against a member firm for three alleged violations related to the failure to maintain policies and procedures and supervisory systems in compliance...more

Goodwin

FINRA Publishes 2024 Annual Regulatory Oversight Report

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On January 9, 2024, FINRA published its 2024 Annual Regulatory Oversight Report (the “Report”). FINRA publishes the Report as a way to provide its broker-dealer members with insight into findings from FINRA’s Member...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Goodwin

SEC EXAMS Division Announces 2024 Priorities Ahead of Schedule

Goodwin on

On October 16, 2023, the SEC’s Division of Examinations (EXAMS) published its exam priorities for 2024. The timing is notable, with the release coming several months ahead of the typical timeline and only eight months after...more

Goodwin

Financial Services Weekly News Roundup - February 2023

Goodwin on

Federal Reserve Issues Policy Statement on Section 9(13) of the Federal Reserve Act - On January 27, the Federal Reserve issued a policy statement interpreting section 9(13) of the Federal Reserve Act, which authorizes...more

Carlton Fields

FINRA Issues 2023 Report on Examination and Risk Monitoring Program

Carlton Fields on

On January 10, 2023, FINRA issued its 2023 Report on FINRA’s Examination and Risk Monitoring Program to provide “insight into findings from the recent oversight activities of FINRA’s Member Supervision, Market Regulation and...more

Goodwin

FINRA on Reg. BI Compliance: There is “No One-Size Fits All” Approach

Goodwin on

​​​​​​​FINRA recently hosted a conference call with its smaller members covering Regulation Best Interest and Form CRS compliance. FINRA’s resounding message was that there is “no one-size-fits all” approach to Reg. BI...more

Goodwin

FINRA Proposes to Publicly Identify “Restricted Firms” on BrokerCheck

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BrokerCheck is the database through which FINRA publishes licensing, registration, and disciplinary history of brokerage industry firms and their personnel. BrokerCheck does not currently specify whether a particular firm is...more

Goodwin

SEC Examinations Division Publishes 2022 Priorities

Goodwin on

The SEC Division of Examinations recently published its list of priorities for 2022. While it was a bit late compared to a typical year, the priorities letter provides a roadmap for firms to better understand where the...more

Moore & Van Allen PLLC

SEC Announces Exam Priorities for 2022

On March 30, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations released its exam priorities for fiscal year 2022 (the “2022 Priorities”). As in years past, these exam priorities naturally...more

Faegre Drinker Biddle & Reath LLP

Exam Time: FINRA Releases its 2022 Report on its Examination and Risk Monitoring Program

A common phrase to abide by in the New Year is “out with the old, in with the new.” FINRA’s 2022 Report on its Examination and Risk Monitoring Program (the “Report”), however, contains a combination of old and new priorities....more

Burr & Forman

FINRA’S 2022 Report on Examination & Risk Monitoring Program

Burr & Forman on

Over the last couple of decades, the securities self-regulatory organization FINRA (f/k/a NASD) informs its membership each year of what compliance risks are noted by its examination program. Those are risks firms should...more

Faegre Drinker Biddle & Reath LLP

Brace for Impact: It’s Going to be (Another) Busy Year for FINRA

F. Scott Fitzgerald said “There are only the pursued, the pursuing, the busy, and the tired.” FINRA may be all of these in 2022, as FINRA CEO Robert Cook announced FINRA’s laundry list of priorities during a SIFMA Q&A last...more

Kilpatrick

Insights into the States' 2021 BD Examination, Enforcement Priorities

Kilpatrick on

Putting Teeth on Reg BI (to take a bite out of complex products sales), Protecting Seniors (from romance scams, affinity frauds, and rogue POAs), Scrutinizing Bank-Based Reps, DBAs, and Remote Supervision, and the beginning...more

Latham & Watkins LLP

SEC Staff Issues No-Action Relief to Broker-Dealers From Reg BI and Form CRS Obligations Related to Certain Family Offices

Latham & Watkins LLP on

The no-action relief applies to family offices with at least US$50 million in total assets (Institutional Family Offices) and requires broker-dealers seeking to rely on the relief to establish and maintain specific additional...more

Bressler, Amery & Ross, P.C.

Maxine Waters Presses Biden to Rescind Reg BI

President-Elect Joe Biden is quickly learning that the line of people seeking regulatory reform in the wake of the Trump administration's regulatory free-for-all is getting longer all the time. At the front of the line is...more

Faegre Drinker Biddle & Reath LLP

SEC Roundtable on Reg BI and Form CRS

The U.S. Securities and Exchange Commission (SEC) hosted a virtual roundtable in late October to discuss the Regulation Best Interest (Reg BI) and Form CRS. With a few months of observations from examinations since the June...more

Goodwin

U.S. SEC Chairman Confirms June 30th Deadline and Areas of Focus for Regulation Best Interest and Form CRS

Goodwin on

In a public statement issued on June 15, 2020, U.S. Securities and Exchange Commission (SEC) Chairman Clayton confirmed the June 30, 2020, deadlines for compliance with Regulation Best Interest (Reg. BI) and the Form CRS...more

WilmerHale

Navigating the "Good Faith Effort" Standard for Reg BI and Form CRS Implementation

WilmerHale on

Firms must demonstrate a “good faith effort” to comply. Last month, SEC Chairman Clayton issued a public statement communicating that firms should not expect a delay of the June 30, 2020 compliance date for Regulation Best...more

K&L Gates LLP

OCIE Issues Guidance for Examinations of Regulation Best Interest and Form CRS

K&L Gates LLP on

The June 30 deadline for compliance with Regulation Best Interest [1] and Form CRS [2] presents new compliance obligations for broker-dealers and investment advisers engaging in a retail business. In anticipation of this...more

Polsinelli

BitBlog Bi-Weekly Update - April 2020

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While the world at large shelters in place due to COVID-19 legal and regulatory activity of digital asset and the blockchain world is hopping. ...more

Epstein Becker & Green

SEC and FINRA Provide Guidance on Regulation Best Interest

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Recently, the U.S. Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide broker-dealers with guidance on examinations regarding regulation Best...more

Lowenstein Sandler LLP

Form CRS Drafting Guide and Template

Lowenstein Sandler LLP on

What You Need To Know; • The Form CRS must be filed with the SEC by June 30, 2020, at the latest. • All investment advisers, broker-dealers, or dual registrants that service retail investors may now file the Form CRS with the...more

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