529 Plans are state-sponsored investment programs that facilitate savings for qualified education expenses, including tuition, fees, room and board, and other education-related expenses. Unlike retirement accounts that...more
The new initiative promises standard settlements for qualifying self-reported violations. On January 28, 2019, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 19-04 announcing its 529 Plan...more
The Securities and Exchange Commission (SEC) has proposed a new rule and related amendments designed to streamline and enhance the regulatory framework for "fund of funds" arrangements....more
On January 28, 2019, the Financial Industry Regulatory Authority, Inc. (FINRA) launched its 529 Plan Share Class Initiative (the Initiative) to encourage member firms to self-report potential violations of rules governing 529...more
On January 28, 2019, FINRA announced a novel leniency initiative that will offer no-fine enforcement resolutions for member firms that self-report supervisory deficiencies related to recommendations of 529 savings plans and...more
About a year ago, the SEC offered investment advisors the unique opportunity to report themselves to the SEC if they sold mutual funds to their clients that offered a lower priced share class than the class actually selected...more
On December 22, 2017, the tax reform bill, informally known as the Tax Cuts and Jobs Act (the “Act”), was signed by President Trump. As we noted in our prior OnPoint (available here) with respect to earlier versions of the...more
A recent SEC no-action letter gives broker-dealers more time to perform suitability and other reviews when opening certain customer accounts. The firms requesting the letter were affiliated with three different insurance...more
In July, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) announced an initiative to identify instances where registered investment advisers may be improperly influenced by...more
The Securities and Exchange Commission Adopts Amendments to Form ADV and Investment Adviser Act Rules - The Securities and Exchange Commission (SEC) adopted amendments to Form ADV and Investment Advisers Act of 1940...more
OCIE recently published a Risk Alert announcing that it will examine the potential conflict of interest created by registered investment advisers being financially incentivized to recommend certain share classes to clients....more
On January 12, 2016, the Securities and Exchange Commission’s Division of Corporation Finance (the “Division”) granted no-action relief to the College Savings Plan Network (“CSPN”), an affiliate of the National Association of...more
The SEC and FINRA recently extended relief originally granted to accommodate suitability reviews of deferred variable annuities, so that the relief is now also available for mutual funds, Section 529 plans, and other...more