Financial Services Weekly News: OCIE Issues Risk Alert On Investment Adviser Principal And Agency Cross Trading Compliance


Regulatory Developments

OCIE Issues Risk Alert on Investment Adviser Principal and Agency Cross Trading Compliance Issues

On September 4, the Office of Compliance Inspections and Examinations (OCIE) of the SEC issued a risk alert highlighting the most common deficiencies identified in investment-adviser examinations regarding principal trading and agency cross transactions when acting as a broker. In general, investment advisers are not permitted to (1) buy or sell a security from a client for its own account (principal trades) or (2) act as a broker for a person who is not a client and effect a sale or purchase of a security for the account of that client (agency cross transactions), without disclosure and consent from such client (with certain limited exceptions in the case of agency cross transactions). These deficiencies include non-compliance with consent and disclosure requirements of Section 206(3) of the Investment Advisers Act of 1940, as amended (Advisers Act), both in the context of individual-account clients and pooled investment vehicles (where such vehicles had significant ownership overlap), and non-compliance with the requirements relating to agency cross transaction contained in Rule 206(3)-2 promulgated under the Advisers Act. In addition, OCIE identified advisers that either did not have, or failed to follow, sufficient policies and procedures relating to principal and agency cross trading. OCIE concludes the risk alert by encouraging advisers to review and revise policies and procedures as appropriate to comply with Advisers Act requirements around principal and agency cross trading.

Goodwin Alert: SEC Issues Guidance Regarding Proxy Voting Process

On August 21, as previously covered by the Roundup, the SEC published two guidance releases regarding the proxy voting process. The first release is guidance to assist investment advisers (or fund managers) who assume voting responsibility on behalf of their clients, particularly with respect to the use of recommendations from proxy advisory firms, such as ISS and Glass Lewis (the Investment Advisers Guidance). The second release is an interpretation and guidance regarding the applicability of the federal proxy rules to voting recommendations made by proxy advisory firms (the Proxy Rules Guidance). The SEC approved both releases by a 3-2 vote, with Chairman Clayton and Republican Commissioners Peirce and Roisman forming the majority in each vote and Democratic Commissioners Jackson and Lee dissenting. For more information, read the client alert issued by Goodwin’s Public Companies and Investment Management practices.

Goodwin Alert: Inline XBRL Interpretations Issued by SEC Staff

The staff of the Division of Corporation Finance of the SEC has published nine Compliance and Disclosure Interpretations (C&DIs) relating to the Inline XBRL rules adopted in June 2018 (discussed in this Goodwin alert) and March 2019 (discussed in this Goodwin alert). The C&DIs clarify some questions about how companies should list exhibits in SEC filings, the impact of voluntarily filing documents that contain Inline XBRL, and transition issues for foreign private issuers. Note that at this time only large accelerated filers (including foreign private issuers that are large accelerated filers and prepare their financial statements in accordance with U.S. GAAP) are subject to the Inline XBRL rules. For more information, read the client alert issued by Goodwin’s Public Companies practice.

SEC Announces Increased Filing Fees for Fiscal Year 2020

On August 23, the SEC announced that the fees that public companies and other issuers (including mutual funds) pay to register their securities with the SEC will increase approximately 7.1% from $121.20 per million dollars to $129.80 per million dollars. The change will be effective on October 1, 2019. The fee rate change will apply not only to registration fees payable under Section 6(b) of the Securities Act of 1933, but also to fees payable under Section 13(e) and Section 14(g) of the Securities Exchange Act of 1934, in connection with securities repurchases and certain proxy solicitations and statements in corporate control transactions, respectively. The Section 6(b) rate is also used to calculate fees payable with an Annual Notice of Securities Sold Pursuant to Rule 24f-2 under the Investment Company Act of 1940. Because a mutual fund is required to pay its annual registration fee within 90 days after its fiscal year end, funds with fiscal years ending July 31st or August 31st have the flexibility to pay such fees before the higher fee rate takes effect. Any such fund that ordinarily would make its annual fee filing after October 1, 2019, may be able to achieve meaningful cost savings by choosing to do so before 5:30 p.m. ET on September 30, 2019 (i.e., the last business day before the rate hike). The SEC filing fee estimator is available here.

FFIEC Member Agencies Update Flood Insurance Exam Manual

On August 22, the FFIEC member agencies updated the Interagency Examination Procedures for the Flood Disaster Protection Act. The revised procedures reflect a February 2019 final interagency rule that addresses the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012. These procedures incorporate new sections that discuss the following aspects of the final private flood insurance rule:

  • mandatory acceptance of a private insurance policy to satisfy the flood insurance purchase requirement if the policy meets the statutory and regulatory definition of “private flood insurance;”
  • discretionary acceptance of a flood insurance policy issued by a private insurer, even if the policy does not meet the statutory and regulatory definition of “private flood insurance;” and
  • discretionary acceptance of a plan issued by a mutual aid society in satisfaction of the flood insurance purchase requirement, if certain criteria are met.

FFIEC Encourages Standardized Approach to Assessing Cybersecurity Preparedness

On August 28, the FFIEC member agencies emphasized the benefits of using a standardized approach to assess and improve cybersecurity preparedness. The members note that firms adopting a standardized approach are better able to track their progress over time and share information and best practices with other financial institutions and with regulators. The agencies noted that institutions may choose from a variety of standardized tools aligned with industry standards and best practices to assess their cybersecurity preparedness. These tools, which are included in the guidance, include the FFIEC Cybersecurity Assessment Tool, the National Institute of Standards and Technology Cybersecurity Framework, the Financial Services Sector Coordinating Council Cybersecurity Profile, and the Center for Internet Security Critical Security Controls.

FDIC Clarifies Its Risk-Focused Approach to Exam Policies

On August 27, the FDIC announced updates to its Risk Management Manual of Examinations Policies to incorporate a new section titled Risk-Focused, Forward-Looking Safety and Soundness Supervision. The new section describes communication and risk-tailoring principles followed during safety and soundness examination activities and the FDIC’s long-standing examination philosophy and methods, improves transparency of the FDIC’s examination practices, and reinforces the expectations placed on FDIC supervisory staff to conduct risk-focused, forward looking supervision.

Enforcement & Litigation

Goodwin Alert: Federal Government Advocates Industry-Friendly Position In ESOP Stock Drop Supreme Court Case

Recently, the U.S. Supreme Court granted a writ of certiorari to hear Retirement Plans Committee of IBM v. Jander, a case about the legal standard for pleading a claim for breach of fiduciary duties under the Employee Retirement Income Security Act (ERISA) following a drop in the value of employer stock. In December of last year, the Second Circuit ruled that a participant in a publicly-owned company employee stock ownership plan (ESOP) could state a claim for breach of fiduciary duty against the ESOP fiduciary by pleading: (1) that the fiduciary failed to act on the basis of non-public information that would eventually have to be disclosed; and (2) that the fiduciary could not have concluded that earlier disclosure of the information would have done more harm than good. Jander v. Retirement Plans Comm. of IBM, 910 F.3d 620 (2d Cir. 2018). After petitioners filed their brief, on August 13, 2019, the Department of Labor (DOL) and the SEC signed on to an amicus brief filed by the Solicitor General on behalf of the United States, advocating that the Supreme Court adopt narrower interpretation than the Second Circuit: the Solicitor General argued that the Court should hold that ESOP fiduciaries are required to disclose non-public information only when required by federal securities laws. If the Supreme Court accepts that view, then it will overturn the Jander decision, and plaintiffs will face a high bar to plead a fiduciary breach in ESOP stock-drop cases where they cannot plausibly allege a violation of the securities laws—a result that is consistent with the view taken by more than a dozen courts considering the same issue, before the Second Circuit decided Jander. Read the client alert issued by Goodwin’s ERISA Litigation practice.

Seventh Circuit Imposes Strict Requirements for FDCPA Validation Notices Delivered Via Email

On August 8, the Seventh Circuit, in Lavallee v. Med-1 Solutions, LLC, 932 F.3d 1049 (7th Cir. 2019), ruled that emails to consumers from debt collects containing hyperlinks to information regarding debt, including validation notices, are not “communications” under the Fair Debt Collection Practices Act (FDCPA). Therefore, the court held, the emails do not provide consumers with the required validation notices under Section 1692g(a) of the FDCPA. In Lavallee, the consumer plaintiff brought a class action against the debt collector, alleging the email communications sent to the consumer failed to include disclosures required by the FDCPA regarding the amount of the debt, the consumer’s right to dispute the debt, and how to obtain more information about the alleged creditor. The debt collector had sent the consumer two emails, each concerning a separate debt, which did not include any information as to the debt and did not provide validation notices on the face of the emails, but which did provide the required information and disclosures in embedded hyperlinks. Read the LenderLaw Watch blog post.

CFPB Announces $236,000 Settlement With Illinois Debt Collector

On August 28, the CFPB announced a settlement with an Illinois-based debt collection company, resolving allegations that the company engaged in deceptive practices in violation of the Consumer Financial Protection Act (CFPA), 12 U.S.C. §§ 5531 and 5536, and the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. § 1692e. Read the Enforcement Watch blog post.

FTC Announces $30 Million Settlement With Operator of For-Profit Post-Secondary Schools

On August 27, the Federal Trade Commission (FTC) announced it had reached a $30 million settlement with an Illinois-based operator of for-profit post-secondary schools and related subsidiaries resolving allegations that the company used lead generators who engaged in deceptive conduct to market its schools in violation of Section 5(a) of the Federal Trade Commission Act, 15 U.S.C. § 45(a). According to the FTC, lead generators represented to consumers that the company’s schools were associated with the military when they were not. The lead generators also allegedly called consumers on the National Do-Not-Call Registry in violation of the FTC’s Telemarketing Sales Rule, as amended, 16 C.F.R. Part 310. The FTC’s complaint claims that the company knew or approved of the lead generators’ acts and practices, and/or benefitted from those acts and practices. Read the Enforcement Watch blog post.

CFPB and Arkansas AG Settle with Brokers Over Illegal Credit Contracts

On August 14, the CFPB and the Office of the Arkansas Attorney General (AG) entered into a proposed stipulated final judgment with three corporations that brokered extensions of credit to consumers, and the co-founder and owner of one of the corporations. The simultaneously filed complaint, filed in the U.S. District Court for the Eastern District of Arkansas, alleged that defendants engaged in unfair and deceptive acts and practices in violation of CFPA, and deceptive, unconscionable, and false practices in violation of the Arkansas Deceptive Trade Practices Act, by allegedly brokering contracts between consumers (the majority of whom were military veterans) and investors whereby consumers received lump-sum payments in exchange for assigning to the investors part of their monthly pension or disability payments. These transactions were void under federal law, which prohibits assigning a veteran’s pension payments to another person. Additionally, defendants allegedly misrepresented to consumers that these products were sales of payments rather than high-interest credit offers, and failed to disclose to consumers the interest rates of these products. Read the Enforcement Watch blog post.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

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Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

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How is your information shared?

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How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

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Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
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You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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There are different types of cookies and other technologies used our Website, notably:

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JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

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Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

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