UPDATE: As of December 30, 2020, Arizona, Arkansas, Michigan, and Rhode Island have joined Iowa in adopting the NAIC model rule for best interest standard in annuity sales. Alabama, Delaware, Kentucky, Maine, Nevada and Ohio...more
The Securities and Exchange Commission ("SEC") staff hosted a roundtable with the Financial Industry Regulatory Authority ("FINRA") on October 26, 2020, to discuss their observations on the implementation of, and compliance...more
On September 15, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a cybersecurity risk alert highlighting the increased use of “credential stuffing” attacks against investment advisers and...more
In April and May 2020, the Securities and Exchange Commission (the “Commission”) entered a series of settled Orders assessing fines, instituting a bar, and ordering remedial action against registered investment advisers...more
Many registered investment advisers (“RIAs”) have obtained loans guaranteed by the U.S. Small Business Administration (SBA) under the Paycheck Protection Program (“PPP”). Applicants for PPP loans were required to make certain...more
UPDATED: MAY 12, 2020: Yesterday, Iowa adopted its proposed regulation requiring annuity agents to act in the best interest of consumers, but delayed adoption (or revision, withdrawal) of the companion securities rules. The...more
Section 17(a) of the Investment Company Act of 1940, as amended (the “40 Act”) prohibits certain transactions between an investment company and their affiliated persons, including transactions where an affiliated person...more
On February 21, 2020, the Massachusetts Securities Division (the “MSD”) announced the finalization of its fiduciary rule. Part I summarized the evolution of Massachusetts Fiduciary Rule (“Fiduciary Rule”) and the...more
On February 21, 2020, the Massachusetts Securities Division (the “Securities Division”) announced the finalization of its Fiduciary Rule.
This Part I summarizes the evolution of the Massachusetts Fiduciary Rule and the...more