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Investment Adviser Broker-Dealer

Colorado Proposes Cybersecurity Rules for Investment Advisers, Broker-Dealers

by Ballard Spahr LLP on

The Colorado Division of Securities recently issued proposed rules directed at establishing cybersecurity requirements for broker-dealers and investment advisers. The proposed rules were issued only a month after New York...more

Who Does What: Broker Dealers | Registered Investment Advisers | Commodities/Futures Entities

by Fox Rothschild LLP on

At Fox Rothschild LLP, we have a wealth of experience in creating and forming broker-dealers, registered investment advisers, commodity entities and various hedge funds. Over the years, our strategy has been to work with our...more

New York Department of Financial Services Provides Guidance on Cybersecurity Regulation; Colorado Financial Regulator Proposes...

In April 2017, the New York Department of Financial Services (the “DFS”) released guidance on interpreting 23 NYCRR Part 500, its recently promulgated regulation that requires banks, insurance companies and other financial...more

Colorado Regulator Proposes New Cybersecurity Rules for Financial Institutions

Increasingly, states are enacting cybersecurity regulations for financial institutions and investment advisors. Following New York’s groundbreaking regulation, Colorado recently proposed changes to its state...more

Regulatory Update and Recent SEC Enforcement Actions

by Blank Rome LLP on

REGULATORY UPDATE - Ten Investment Advisory Firms Subject to Steep Penalties after Violating Pay-to-Play Rules - In January 2017, 10 investment advisory firms agreed to settle with the U.S. Securities and Exchange...more

Securities Legislative Update – Elderly Investors 2017

The SEC recently approved FINRA’s proposed rule aimed at preventing fraud and abuse of senior investors. On March 30, FINRA issued Regulatory Notice 17-11, setting the effective date for the new rule as February 5, 2018. The...more

State of Colorado Proposes Financial Services Cybersecurity Requirements

Following in the footsteps of the State of New York, the Colorado Department of Regulatory Agencies has proposed amendments to the Colorado Securities Act to require investment advisers and broker-dealers to implement new...more

SEC Approves FINRA Efforts to Protect Seniors and Other Vulnerable Persons

by Carlton Fields on

The SEC recently approved an amendment to FINRA Rule 4512 that requires FINRA members to make reasonable efforts to obtain, from each customer for whom they maintain an account, specified information about a “trusted contact...more

"DOL Finalizes Delay of Conflict of Interest Rule"

On April 4, 2017, the Department of Labor (DOL) released its final rule providing a 60-day delay of the April 10, 2017, applicability date of its conflict of interest regulation (the so-called fiduciary rule) and related...more

Colorado Proposes Cybersecurity Requirements for Investment Advisers and Broker-Dealers

by BakerHostetler on

On March 27, 2017, the Colorado Department of Regulatory Agencies proposed changes to the Colorado Securities Act that would impose new cybersecurity requirements on investment advisers and broker-dealers (the “Proposed...more

The problem with Morgan Stanley’s payment decision

by Ary Rosenbaum on

As you probably heard, Morgan Stanley will be moving to a level compensation approach for its 401(k) advisors. So this means it will do away with commission payments and finder’s fees (for recommending record-keeping...more

Funds Talk: April 2017

SEC Offers Guidance on ‘Fast-Growing Trend’ of Robo-Advisers - As technology and robo-advisers become increasingly common options for asset managers and investors alike, the SEC is taking a closer look at some of the...more

FINRA Seeks Comments on its Engagement Programs

by Dechert LLP on

The Financial Industry Regulatory Authority (FINRA), on March 21, 2017, published a Special Notice soliciting comments on various existing FINRA engagement programs (Notice). This request for comment is one component of...more

Asset Managers: Are You Ready for Your Exam? Steps You Should Take Now

by Sullivan & Worcester on

Last week we told you about the five biggest pet peeves of the SEC’s Office of Compliance Inspections and Examinations (OCIE) when examining investment advisers. This week, we want to get you ready for your exam. Here are the...more

DOL Announces Temporary Enforcement Policy and Proposes to Extend Application of Rules Under Best Interest Contract Exemption by...

by Jackson Lewis P.C. on

In response to a February 3, 2017 memorandum by the President to the Secretary of Labor, on March 2, 2017, the DOL proposed to extend for 60 days the applicability date for final rules on the Best Interest Contract Exemption...more

SEC Speaks: 2017 Enforcement and Exam Trends for Private Funds

At the recent SEC Speaks program, sponsored by PLI, senior SEC staff members provided valuable insight into the SEC’s 2017 priorities for private funds. While the tenor of this year’s discussion seemed to focus more on...more

Certain Companies that May be Subject to FDIC Orderly Liquidation Authority under Dodd-Frank are Now Subject to Qualified...

by Dechert LLP on

Companies that the Financial Stability Oversight Council (FSOC) believes may be subject to FDIC receivership under the Orderly Liquidation Authority contained in Title II of the Dodd-Frank Act, and certain of their...more

SEC Fines Broker-Dealer for Inadequate Information Barriers

by Dechert LLP on

The U.S. Securities and Exchange Commission (SEC) on February 13, 2017, issued a cease and desist order (Order) and imposed a $100,000 civil penalty against broker-dealer Sidoti & Company, LLC (Broker-Dealer), to settle...more

2016 Year in Review: Select SEC and FINRA Developments and Enforcement Cases

by Morgan Lewis on

Executive Summary - The Morgan Lewis Year in Review highlights key US Securities and Exchange Commission (the SEC or the Commission) and Financial Industry Regulatory Authority (FINRA) enforcement developments and...more

SEC Staff Issues Guidance Update and Investor Bulletin on Robo-Advisers

On February 23, 2017, the Securities and Exchange Commission (“SEC“) published information and guidance for investors and the financial services industry on the use of robo-advisers, described by the Staff as “registered...more

Examination Priorities for 2017 from FINRA and OCIE

by Morrison & Foerster LLP on

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

UPDATE: Continued Regulatory Focus on US Political Contributions

by Dechert LLP on

Recent actions by financial industry regulators, including the Securities and Exchange Commission (“SEC”), the Financial Industry Regulatory Authority, Inc. (“FINRA”), and the Municipal Securities Rulemaking Board (“MSRB”),...more

Investment Advisers And Broker-Dealers Face Scant Likelihood Of California Examinations

by Allen Matkins on

The California Department of Business Oversight recently issued a report on its Broker-Dealer/Investment Adviser Program. This report was required by the Budget Act of 2014. Although short, the report provides some...more

OCIE and FINRA Announce 2017 Examination and Regulatory Priorities

by K&L Gates LLP on

On January 4 and January 12, 2017, respectively, the Financial Industry Regulatory Authority (“FINRA”) and the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) each...more

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Cybersecurity

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