On June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted three to one to approve a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with investment advisers and broker-dealers (the “June 5 Release”). Adopted pursuant to the broad rulemaking authority granted in Section 913(f) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the June 5 Release consists of the following four components:

1. Regulation Best Interest: The Broker-Dealer Standard of Conduct (“Reg BI”) (Applies to Broker-Dealers; Compliance Date June 30, 2020);

2. Form CRS Relationship Summary; Amendments to Form ADV (“Form CRS”) (Applies to Broker-Dealers and Registered Investment Advisers; Compliance Date June 30, 2020);

3. Commission Interpretation Regarding Standard of Conduct for Investment Advisers (“Fiduciary Interpretation”) (Applies to all Investment Advisers; Effective July 12, 2019); and

4. Commission Interpretation Regarding the Solely Incidental Prong of the Broker-Dealer Exclusion from the Definition of Investment Adviser (“Solely Incidental Interpretation”) (Applies to Broker-Dealers; Effective July 12, 2019).