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Structured Thoughts: News for the financial services community Volume 9, Issue 4

SEC FINES BROKER-DEALER FOR EARLY RESALES OF STRUCTURED NOTES - On June 25, 2018, the SEC announced that a broker-dealer settled charges relating to inappropriate resales of structured notes. The SEC determined that the...more

SEC Proposes Simplified Relationship Summary for Broker-Dealers and Investment Advisers to Use with Retail Investors

In the third release comprising part of the package of proposed rules and forms related to broker-dealers’ and investment advisers’ standards of conduct, the Securities and Exchange Commission (the SEC or the “Commission”)...more

The SEC's Standard of Conduct Proposals Would Raise the Bar on Investment Advisers

According to the Securities and Exchange Commission (SEC or “Commission”), its April 18, 2018 release proposing an interpretation of the standard of conduct for investment advisers (“Adviser Conduct Release”) is intended to...more

SEC Proposes a New Standard of Care for Broker-Dealers: Regulation Best Interest

Background - For many years, the distinction between investment advisers and broker-dealers was clear: investment advisers were counselors who were expected to provide advice that was in the best interest of their clients,...more

Understanding the Standard of Care for Broker-Dealers and the Department of Labor’s Fiduciary Rule

Until recently, broker-dealers operating in the United States weren’t subject to a fiduciary standard when dealing with their retail clients. The passage of the Dodd-Frank Act in 2010 included a provision enabling the...more

SEC Chairman Clayton Addresses Senate Committee

On September 26, 2017, SEC Chairman Jay Clayton delivered to the U.S. Senate Committee on Banking, Housing and Urban Affairs his first testimony as Chairman. ...more

Examination Priorities for 2017 from FINRA and OCIE

In these uncertain times, the predictability and regularity of the annual priorities letters from FINRA and the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) is...more

Structured Thoughts: News for the financial services community, Volume 8, Issue 2

Identifying Conflicts of Interest in Structured Products Offerings - With FINRA and other regulators focused on conflicts of interest in the broker-dealer industry, market participants are working diligently to identify...more

FINRA Investor Education Foundation Announces Investor Survey Results

On December 13, 2016, the FINRA Investor Education Foundation published Investors in the United States 2016 (the “Report”), which includes the results of its investor survey of 2,000 individuals from across the United States...more

“It’s Not a Culture War” – Yet?

On May 23, 2016, at FINRA’s annual conference in Washington, D.C., Richard Ketchum, FINRA’s chairman and CEO, delivered a speech that shed a little light on FINRA’s recent sweep letter relating to firm culture....more

Structured Thoughts: News for the financial services community, Special Issue: Implications of the DOL Fiduciary Rule for...

On April 6, 2016, the Department of Labor (“DOL”) issued its final conflict of interest regulations, which significantly expand who is considered a fiduciary when dealing with a retirement account. The new regulations,...more

Cybersecurity, Round 2: OCIE Announces Areas of Focus for Cybersecurity Examinations

On September 15, 2015, OCIE issued a risk alert relating to its new cybersecurity examination initiative. This is the second round of these examinations, and the alert provides a detailed look at OCIE’s current areas of...more

Structured Thoughts: News for the financial services community, Volume 5, Issue 9

In This Issue: - What to Expect in 2015 - EU Regulatory Agenda: Into 2015 - FINRA Issues Report Relating to its Communication Rules - Structured Product Offerings and RIAs - The SEC, Investment Funds and...more

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