News & Analysis as of

Investment Advisers Act of 1940 SIFMA

Morrison & Foerster LLP

SEC Targets "AI Washing" With Two New Settled Cases

On March 18, 2024, the SEC announced—in videos posted on YouTube and Twitter—regulatory actions against two investment advisers for “AI washing,” a practice defined by the SEC as “making false artificial intelligence-related...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Seward & Kissel LLP

Expiration of SEC Staff’s No Action Letters Providing Relief to Broker-Dealers Regarding MiFID II Research Requirements

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Expiration of SEC Staff’s No Action Letters Providing Relief to Broker-Dealers Regarding MiFID II Research Requirements - On July 3, 2023, the U.S. Securities and Exchange Commission (the “SEC”) let expire a long-standing...more

Bracewell LLP

FINRA Facts and Trends: May 2023

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Welcome to the latest issue of Bracewell’s FINRA Facts and Trends, a monthly newsletter devoted to condensing and digesting recent FINRA developments in the areas of enforcement, regulation and dispute resolution. This...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

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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

Winstead PC

It’s the Final Countdown: Being Prepared for Regulation Best Interest

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Last year the U.S. Securities and Exchange Commission (“SEC”) approved Regulation Best Interest (“Reg BI”). Reg BI requires broker-dealers and their associated persons to act in “the best interest” of a retail customer when...more

Blank Rome LLP

Regulatory Update and Recent SEC Actions - April 2019

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REGULATORY UPDATES - Financial Industry Regulatory Authority (“FINRA”) Releases Its 2019 Priorities - On January 22, 2019, FINRA released its Annual Risk Monitoring and Examination Priorities Letter, which highlighted the...more

Proskauer Rose LLP

Analysis of the SEC’s MiFID II No-Action Relief

Proskauer Rose LLP on

On October 26, 2017, the Securities and Exchange Commission ("SEC" or the "Commission") staff issued three no-action letters to help broker-dealers, investment advisers and investment companies comply with the European...more

Dechert LLP

SEC Principal Trading Rule Exemption Set to Expire at Year’s End

Dechert LLP on

The staff of the U.S. Securities and Exchange Commission (SEC) stated in August that it intends to permit the expiration of rule 206(3)-3T (Rule) under the Investment Adviser Act of 1940 (Advisers Act). The SEC originally...more

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