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Expect Focus - Volume I, January 2024

Funds Not Caged by SEC Names Rule Amendments: Roaming Room Remains - The SEC recently adopted amendments to its investment company “names” rule that apply to most SEC-registered funds, including underlying funds in which...more

New York Department of Financial Services Plays Pit Boss for Consumer Protection

Worried that the cards may be stacked against certain consumers and producers, the New York Department of Financial Services (DFS) released a circular letter and filing guidance note on July 17 to remind insurers of their...more

Expect Focus - Volume II, May 2023

For broker-dealers distributing and selling variable annuities, examinations will test for compliance with Reg BI and FINRA Rule 2330 because both standards apply to variable annuity sales. Firms distributing and selling...more

Opening Day: Regulators Showcase Big Data Initiatives at NAIC Spring Meeting

Few things thrill baseball fans more than opening day. They come with a mix of excitement and trepidation. For many of them, it’s the first day they get to see their favorite team showcase its talents, and their first glimpse...more

Expect Focus - Volume I, January 2023

More than 25 years have elapsed since the SEC adopted Exchange Act Rule 17a-4(f) governing electronic recordkeeping by broker-dealers. In an effort to update the rule to reflect “technology neutral” concepts, the SEC adopted...more

Does Colorado’s Draft Big Data Governance Rule Foretell of a Long Winter or an Early Spring?

Colorado Senate Bill (SB) 21-169, which became law in 2021, is intended to “hold insurers accountable for testing their big data systems — including external consumer data and information sources, algorithms, and predictive...more

SEC Issues Cybersecurity Disclosure Guidance

On February 21, the SEC published interpretive "Guidance" to help public operating companies prepare disclosures about cybersecurity risks and incidents. ...more

SEC Sidelines Funds Focused on Cryptocurrencies

In a January 18 letter to two of the fund industry’s leading advocacy groups, the staff of the SEC’s Division of Investment Management advised fund sponsors not to initiate registration of funds that intend to invest...more

Expect Focus - Volume IV, December 2017

EXPECTFOCUS is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Regulators Continue to Scrutinize Initial Coin Offerings

As reported in the most recent issue of Expect Focus, the SEC issued an investigative report in July cautioning market participants that distributed ledger (blockchain) technology-based offers and sales of digital "tokens" or...more

Expect Focus - Volume III - September 2017

EXPECTFOCUS® is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

SEC Scrutinizes Multi-Manager Arrangements

Many mutual funds implement their investment strategies through "multi-manager" (also called "manager of manager") arrangements, particularly funds used to support variable life insurance and annuity products. Among other...more

Back to the Future: 2017 [Expect Focus Life Insurance – December 2016]

- Should Your Company Purchase Bitcoin to Pay a Cyber Ransom? - NAIC Draws Line in CFPB Sandbox - NAIC’s Big Data Task Force Sets Charges for 2017 - Broker-Dealers Can Hold Customers’ Initial Checks...more

Expect Focus - Spot The Regulator, Volume IV, Fall 2014

In This Issue: - IN THE SPOTLIGHT ..Crisis Management: Five Steps to Take Before Providing That Comment - LIFE INSURANCE ..Third Circuit Limits ERISA Fiduciary Liability to those with Ultimate...more

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