A common phrase to abide by in the New Year is “out with the old, in with the new.” FINRA’s 2022 Report on its Examination and Risk Monitoring Program (the “Report”), however, contains a combination of old and new priorities....more
F. Scott Fitzgerald said “There are only the pursued, the pursuing, the busy, and the tired.” FINRA may be all of these in 2022, as FINRA CEO Robert Cook announced FINRA’s laundry list of priorities during a SIFMA Q&A last...more
The U.S. Securities and Exchange Commission (SEC) hosted a virtual roundtable in late October to discuss the Regulation Best Interest (Reg BI) and Form CRS. With a few months of observations from examinations since the June...more
On October 8, 2020, the U.S. Securities and Exchange Commission (SEC) released a joint statement by SEC Chairman Jay Clayton and the SEC’s directors of the Division of Investment Management and the Division of Trading and...more
All things come to those who wait … even Regulation Best Interest (colloquially known as Reg BI). In what now feels like a lifetime since the Securities and Exchange Commission (SEC) adopted it (believe it or not, it was only...more
The SEC has issued guidance addressing the Form CRS. The first is a Risk Alert from the Office of Compliance Inspections and Examinations (OCIE) indicating that OCIE will be looking for good faith compliance when it conducts...more
The Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) will be looking for good faith compliance when it conducts examinations of Form CRS after the June 30, 2020 compliance...more
In light of the significance of the final rules and Commission interpretations issued by the Securities and Exchange Commission (SEC) on June 5, 2019, our Best Interest Compliance Team issued a series of articles on the...more
As the countdown to the June 30, 2020, date for compliance with Reg BI inches forward, FINRA and the SEC are providing a potpourri of support and information to help firms ensure compliance.
FINRA EFFORTS: FINRA’s...more
12/19/2019
/ Best Interest Standard ,
Broker-Dealer ,
Conflicts of Interest ,
Financial Industry Regulatory Authority (FINRA) ,
Form CRS ,
Investment Adviser ,
Investment Firms ,
Investment Management ,
Regulation Best Interest ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Standard of Conduct ,
Stress Tests
In light of the significance of the final rules and commission interpretations issued by the Securities and Exchange Commission (SEC) on June 5, 2019, Drinker Biddle & Reath’s Best Interest Compliance Team is publishing a...more
On June 5, 2019, the Securities and Exchange Commission (SEC) approved the Regulation Best Interest Final Package, the new disclosure requirements that accompany the financial services industry’s new Regulation Best Interest...more
8/20/2019
/ Broker-Dealer ,
Disclosure Requirements ,
EDGAR ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
Form CRS ,
New Rules ,
Regulation Best Interest ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Transactions ,
Standard of Care ,
Standard of Conduct
In light of the significance of Regulation Best Interest (Reg BI) for the financial services industry, Drinker Biddle & Reath’s Best Interest Compliance Team is publishing a series of articles on the Securities and Exchange...more
8/19/2019
/ Best Interest Standard ,
Broker-Dealer ,
Disclosure Requirements ,
EDGAR ,
Fiduciary Duty ,
Financial Industry Regulatory Authority (FINRA) ,
Form CRS ,
Investment Adviser ,
Investment Management ,
New Rules ,
Regulation Best Interest ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Standard of Conduct
On June 5, 2019, the Securities and Exchange Commission (SEC), led by Chairman Jay Clayton, voted 3 to 1 to approve the four agenda items that encompassed the “Reg BI Package.” These four items were Regulation Best Interest –...more
6/13/2019
/ Broker-Dealer ,
Duty of Care ,
Duty of Loyalty ,
Fiduciary Duty ,
Form CRS ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
New Rules ,
Regulation Best Interest ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Transactions ,
Standard of Conduct