The SEC’s Reg BI – A Completely New Standard or Tinkering Around the Edges?

Orrick, Herrington & Sutcliffe LLP

Last week, the Securities and Exchange Commission (SEC) voted to adopt what is popularly known as “Regulation Best Interest” (often referred to as “Reg BI”). Notwithstanding the name, Reg BI is actually a package of rulemakings and interpretations years in the making and represents the SEC’s attempt to implement a more palatable regulatory regime than the controversial fiduciary rule that the Department of Labor enacted in 2017 (which was ultimately vacated in U.S. Chamber of Commerce v. DOL, No. 17-10238, 2018 WL 1325019 (5th Cir Mar. 15, 2018)). In adopting Reg BI, the SEC said this package will “enhance the standard of conduct that broker-dealers owe to their customers and align the standard of conduct with retail customers’ reasonable expectations” and “will also provide additional transparency and clarity for retail investors through enhanced disclosures designed to help them understand who they are dealing with, and why that matters.”

This package includes several parts:

  • Regulation Best Interest, which requires broker-dealers to act in the “best interest” of retail customers when recommending securities transactions or investment strategies;
  • The Form CRS Relationship Summary, which requires registered investment advisers and broker-dealers to provide retail investors with simple, easy-to-understand information about the nature of their relationship with their financial professional;
  • An interpretation to clarify the SEC’s views on the nature of the fiduciary duties that investment advisers owe to their customers under the Advisers Act; and
  • An interpretation of the “solely incidental” prong of the Advisers Act’s broker-dealer exclusion, which clarifies circumstances in which advisory activities will cause a broker-dealer to be regulated as an investment adviser.

The SEC explained that “[t]he rulemaking package is designed to enhance investor protections while preserving retail investor access and choice in: (1) the type of professional with whom they work, (2) the services they receive, and (3) how they pay for these services.”

The Context of the Changes

Although both broker-dealers and investment advisers serve important functions for retail investors, those functions historically have been distinct – they maintained different types of relationships with their customers, offered different services and used different compensation models. Traditionally, broker-dealers were paid primarily to execute trades on behalf of customers and at their customers’ direction. Investment advisers were paid to counsel customers concerning investment strategies and risks. Because of their role in guiding the investment decisions of their customers, investment advisers have been charged with a fiduciary duty (including a duty of care and a duty of loyalty) towards their customers. Broker-dealers, by contrast, have not been considered fiduciaries and thus have not been held to the higher standard imposed on investment advisers. Instead, broker-dealers historically have been subject to a “suitability” standard, whereby they were required only to have a reasonable basis to believe that a recommended transaction or investment strategy was suitable for the customer based on the customer’s age, financial situation, risk tolerance and other factors.

But the role of broker-dealers has changed over time as the automation of trading has obviated many of their execution responsibilities. Broker-dealers now often perform more of an advisory function for their clients. As a consequence, the SEC has permitted broker-dealers to call themselves financial advisers without imposing fiduciary obligations. The end result is that the lines between broker-dealers and investment advisers have become increasingly blurred, and many retail investors no longer appreciate the distinctions between broker-dealers and investment advisers. In 2006, for example, the SEC commissioned a study by the RAND Corporation that found that participants did not understand the differences between broker-dealers and investment advisers, the legal duties they owe investors, or the meaning of “fiduciary.”

To address this knowledge gap, a 2011 SEC staff study recommended adoption of a uniform fiduciary standard that would govern both broker-dealers and investment advisers. In 2016, the Department of Labor issued a stricter “fiduciary rule” that would have required broker-dealers to handle retirement assets with a heightened duty of loyalty. The Trump administration, however, deferred adopting the fiduciary rule pending further consideration of the issues. Following a legal challenge, the Fifth Circuit vacated the proposed regulation in 2018 on several grounds, including that the Department of Labor had exceeded its authority.

The New Rulemakings and Interpretations

Regulation Best Interest

The final rule implementing Regulation Best Interest enhances the standard of broker-dealer conduct beyond mere suitability requirements. Importantly, the new standard is not co-extensive with the fiduciary obligations of investment advisers, although it incorporates some similar principles and may not be satisfied solely by disclosure. The rule includes the following components:

  • Disclosure Obligation: Broker-dealers must disclose material facts about their relationship with and recommendations made to customers (e.g. fees, the type and scope of services provided, conflicts, limitations on services and products, etc.).
  • Care Obligation: Broker-dealers must exercise reasonable diligence, care and skill when making recommendations to customers. That includes understanding and considering potential risks, rewards and costs associated with their recommendations and making recommendations that are in their customers’ “best interest” only.
  • Conflict of Interest Obligation: Broker-dealers must implement written policies and procedures reasonably designed to identify, and at least disclose if not eliminate, conflicts of interest. Specifically, the policies and procedures must (1) mitigate conflicts that create an incentive for the broker-dealer’s financial professionals to place their interests or the interests of the firm ahead of customers’ interests; (2) prevent material limitations on offerings from causing the firm or its financial professionals to place their interests or the interests of the firm ahead of their customers’ interests; and (3) eliminate sales contests, sales quotas, bonuses and non-cash compensation based on the sale of specific securities or types of securities within a limited period of time.
  • Compliance Obligation: Broker-dealers must implement policies and procedures reasonably designed to achieve compliance with Regulation Best Interest as a whole.

Form CRS Relationship Summary

Pursuant to the Form CRS Relationship Summary, both investment advisers and broker-dealers will be required to deliver a relationship summary to retail investors at the beginning of their relationship. Among other things, the disclosure must concisely (in four pages or less) summarize information about services, fees and costs, conflicts of interest, legal standard of conduct and whether the firm and its financial professionals have any disciplinary history.

Investment Adviser Interpretation

In its investment adviser interpretation, the SEC purports to reaffirm, and in some cases clarify, certain aspects of the principles-based federal fiduciary duty that investment advisers owe to their clients.

The interpretation states that the duty of care requires an investment adviser “to provide investment advice in the best interest of the client, based on the client’s objectives.” To satisfy this obligation, an investment adviser must make a reasonable inquiry into the client’s objectives (updating the client’s investment profile as necessary to reflect changed circumstances) and reasonably believe that the advice given is in the best interest of the client (e.g. by considering whether the client is willing to tolerate the risks of the particular investment and investigating the investment so as to not base the advice on materially inaccurate or complete information). The duty of care also requires an investment adviser to seek best execution of a client’s transactions where the adviser is responsible for selecting broker-dealers to execute the client’s trades, and to provide advice and monitoring at a frequency serving the best interest of the client.

The interpretation also states that the duty of loyalty prohibits an investment adviser from placing its own interests ahead of its client’s interests. To satisfy this duty, the adviser must “make full and fair disclosure to its clients of all material facts relating to the advisory relationship” and “eliminate or at least expose through full and fair disclosure all conflicts of interest which might incline an investment adviser – consciously or unconsciously – to render advice which was not disinterested.”

Solely Incidental Interpretation

In its “solely incidental” interpretation, the SEC purports to confirm and clarify its interpretation of that prong of the broker-dealer exclusion of the Advisers Act. Specifically, a broker-dealer’s advice as to the value and characteristics of securities, or as to the advisability of a securities transaction, is “solely incidental” to the broker-dealer’s business – thereby excluding the broker-dealer from being regulated as an investment adviser – if the advice “is provided with and is reasonably related to the broker-dealer’s primary business of effecting securities transactions.” Thus, if giving advice is the broker-dealer’s primary business or not offered in connection with or reasonably related to the business of executing trades, the services will not qualify for the exclusion. Whether a broker-dealer’s advisory services satisfy the solely incidental prong depends on the facts and circumstances surrounding the business, the services offered and the relationship with the customer.

Key Takeaways

  • Broker-dealers should begin assessing how to implement policies and procedures satisfying Regulation Best Interest. Registered broker-dealers do not need to comply with Regulation Best Interest until June 30, 2020, but they should begin to assess what steps must be taken to ensure compliance. (Those firms that already began to alter their policies and procedures in response to the Department of Labor’s short-lived fiduciary rule might already be ahead of the game.) To be sure, the SEC made it easier for broker-dealers to revise current practices by requiring them to act in clients’ “best interests” and not imposing the same fiduciary obligations that exist for investment advisers. But for those firms that do not already meet the Regulation Best Interest standards, compliance will require a comprehensive assessment of what policies and procedures need to be put in place, creating and implementing those policies and procedures, training on those policies and procedures, and a method for ensuring ongoing adherence.
  • Broker-dealers may need to wait to find out what “best interest” means in practice. Regulation Best Interest – which leaves the term “best interest” undefined – is not a model of clarity. In fact, SEC Commissioner Robert J. Jackson Jr. commented in a scathing dissent from the new rules and interpretations that “the core standard of conduct set forth in Regulation Best Interest remains far too ambiguous about a question on which there should be no confusion.” The SEC contends that it “will enhance the broker-dealer standard of conduct beyond existing suitability obligations.” Indeed, using language almost identical to that in its investment adviser interpretation, Regulation Best Interest prohibits broker-dealers from placing their interests “ahead of the interests of the retail customer.” Others, including Commissioner Jackson, contend that the new rule does not go far enough. In practice, FINRA – not the SEC – is likely to be the frontline enforcer of Regulation Best Interest through its extensive examination and disciplinary programs. The impact of Regulation Best Interest will likely be felt first through the scope of information FINRA seeks in examinations, and future public statements and enforcement actions may better indicate how FINRA interprets the new rule. Until there is more clarity, broker-dealers ought to monitor FINRA and SEC advisories, guidance, and filed and settled actions to conform their conduct over time as closely as possible to the standard.
  • The SEC did not take a position on whether Regulation Best Interest preempts state laws. Unlike the SEC, many states have extended fiduciary obligations to broker-dealers, particularly in recent years as they awaited SEC action in this area. For now, broker-dealers in those states should continue to observe the higher state standard. Ultimately, however, whether Regulation Best Interest displaces those state laws will be determined through litigation. The final rule itself states that “[w]hether Regulation Best Interest would have a preemptive effect on any state law would be determined in future judicial proceedings, and would depend on the language and operation of the particular state law at issue.”
  • The new rules and interpretations likely will have little impact on investment advisers’ current practices. With the exception that investment advisers must provide customers with a relationship summary, the SEC’s new rules and interpretations purportedly do not enhance the obligations already imposed on investment advisers. The SEC maintains that its interpretation only reaffirms (and in some cases clarifies) existing obligations. And Commissioner Jackson contends that the interpretation actually lessens the standard for investment advisers, stating that “the Commission today concludes that investment advisers are not true fiduciaries.” He added that “[t]housands of advisers who have taken pride in putting clients first for decades will be surprised to learn that, all along, the SEC has had lower expectations for their work.” Indeed, the obligation set forth in the SEC’s interpretation to not subrogate clients’ interests (the same standard Regulation Best Interest appears to adopt for broker-dealers) is potentially less onerous than a rule requiring investment advisers to put clients’ interests first. But whether that is the case may very well have to be decided by the courts in the future. In the meantime, it might be safest for investment advisers to stick with the standards they currently observe.

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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