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BD and IA Conflicts of Interest: SEC Staff Says Don’t Set It (Them) and Forget It (Them)

​​​​​​​SEC staff recently served up a juicy staff bulletin covering the standards of conduct for broker-dealer and investment adviser conflicts of interest. The staff bulletin includes 13 Q&As categorized into five different...more

SEC Brings First Ever Regulation Best Interest Litigation Against Broker-Dealer and Its Personnel

The U.S. Securities and Exchange Commission recently charged a broker-dealer and five of its registered representatives with violating Regulation Best Interest (“Reg. BI”) related to recommendations and sales of an unrated,...more

SEC Staff Provides Guidance on Broker-Dealer and Investment Adviser Standards of Conduct For Account and Rollover Recommendations...

U.S. Securities and Exchange Commission staff recently published a bulletin reiterating the standards of conduct applicable to broker-dealers and investment advisers when making account recommendations to retail investors....more

Regulation Best Interest and Form CRS: Spotlight on FINRA’s 2022 Exam and Risk Monitoring Program Report

This is the first in a series of alerts discussing topics covered by FINRA in its 2022 Examination and Risk Monitoring Program Report (the “Report”). Here we take a look at Regulation Best Interest (“Reg. BI”) and Form CRS,...more

SEC Staff Provides Form CRS Observations, Expectations, and Best Practices

On December 17, 2021, the staff of the U.S. Securities and Exchange Commission issued a statement regarding Form CRS disclosures required of SEC-registered broker-dealers and investment advisers who offer services to retail...more

SEC Charges 27 Firms with Form CRS Failures

Word to the wise: when a regulator kindly reminds you on multiple occasions that you need to comply with its rules, you should probably heed those warnings. On July 26, 2021, the SEC announced settlements with 21 investment...more

U.S. SEC Chairman Confirms June 30th Deadline and Areas of Focus for Regulation Best Interest and Form CRS

In a public statement issued on June 15, 2020, U.S. Securities and Exchange Commission (SEC) Chairman Clayton confirmed the June 30, 2020, deadlines for compliance with Regulation Best Interest (Reg. BI) and the Form CRS...more

U.S. Broker-Dealers and Investment Advisers: Prepare for Fast Approaching Regulation Best Interest and Form CRS Deadline

The compliance date of June 30, 2020, is looming for U.S. broker-dealers subject to Regulation Best Interest (Reg. BI) and broker-dealers and investment advisers required to prepare and provide relationship summaries pursuant...more

SEC Exams to Focus on ICOs and Cryptocurrency

On February 7, 2018, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2018 Examination Priorities. In what comes as no surprise, the exam priorities include initial coin offerings (ICOs) and...more

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