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Broker-Dealers and Advisers Beware: The SEC’s “PDA” Proposal Could Upend Firms’ Interactions With Customers, Clients and Investors

On July 26, 2023, the Securities and Exchange Commission (SEC or Commission) narrowly approved (3-2) a proposed rulemaking under the Securities Exchange Act of 1934 (Exchange Act) and the Investment Advisers Act of 1940...more

COVID-19/Market Disruption Update for Investment Managers

The outbreak of the coronavirus (COVID-19) continues to impact markets and business operations in unprecedented ways, which presents risks and opportunities to investment advisers and fund managers. This client alert...more

The Countdown Is On! Building a Reg BI Compliance Program as Deadlines Loom

On June 5, 2019, the SEC adopted a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with broker-dealers and investment advisers. The focal point of this...more

SEC’s Final Rules and Guidance on the Standards of Conduct for Broker-Dealers and Investment Advisers

On June 5, 2019, the Securities and Exchange Commission (“SEC” or “Commission”) in a divided 3-1 vote, approved a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’...more

SEC Share Class Selection Disclosure Initiative: Practical Considerations and Lessons Learned

The Securities and Exchange Commission (“SEC”) has made a concerted effort over the last several years to address investment advisers’ conflicts of interests and to establish standards for associated disclosure failures...more

ETF Boards Need to Apply Gartenberg Differently

The differences between the respective cost structures of exchange-traded funds and mutual funds and the nature of advisory services provided for each product may require boards to think about the Gartenberg factors...more

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