WHERE HAVE YOU GONE, CHIP HILTON?
Somewhere Over the Rainbow
Investment Management Roundtable Discussion – Personal Estate Planning
Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more
Sales of fee-based annuities have soared in recent years. However, the financial planners and investment advisers that use them with clients may be unknowingly exposing themselves to future enforcement action from state...more
New York Pushes Mutual Fund Active Share Disclosure - New York’s Attorney General issued a report on its recent investigation of fees charged by actively managed equity mutual funds and a metric known as “Active Share.”...more
EXPECTFOCUS is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more
On November 24, while everyone was recuperating from their Thanksgiving feast, the NAIC's Annuity Suitability Working Group circulated the Working Group Chair's draft of proposed revisions to the Suitability in Annuity...more
- Should Your Company Purchase Bitcoin to Pay a Cyber Ransom? - NAIC Draws Line in CFPB Sandbox - NAIC’s Big Data Task Force Sets Charges for 2017 - Broker-Dealers Can Hold Customers’ Initial Checks ...more
For two years FINRA has made sales and marketing of L-Share variable annuities (VAs) a regulatory and examination priority. Not surprisingly, FINRA in November announced settled actions against eight broker-dealers, alleging...more
- AXA Prevails at First Post-Jones v. Harris Excessive Fee Trial - Potential Secondary Effects of Regulatory Examinations: Evidentiary Issues and Preclusion in Parallel Litigation - On The Horizon: Global...more
The SEC and FINRA recently extended relief originally granted to accommodate suitability reviews of deferred variable annuities, so that the relief is now also available for mutual funds, Section 529 plans, and other...more
The Department of Labor’s recent Proposed Rule (the “Proposal”), which defines the term “fiduciary” as it applies to persons who provide “investment advice” to ERISA plans and IRAs, will impact the likelihood and severity of...more
In a case involving unsuitable variable annuity (VA) transactions, FINRA found that having good procedures and discovering improper conduct are not enough. A member firm must also ensure that it has adequate supervisory...more
For the first time in several years, variable annuities are not listed as a priority in FINRA’s annual letter of regulatory and examination priorities. The omission from the January 2, 2014, letter may be partly due to the...more