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Form CRS Disclosure Requirements

Morgan Lewis

Compliance Alert: SEC’s 2025 Examination Priorities

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The US Securities and Exchange Commission’s (SEC’s) Division of Examinations released its annual report of examination priorities on October 21, 2024 (the Exam Priorities). The annual Exam Priorities report, which is designed...more

Goodwin

SEC EXAMS Division 2025 Priorities Signal Continued Scrutiny of Broker-Dealers

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The SEC Division of Examinations (EXAMS) recently published its list of priorities for 2025, providing a roadmap for broker-dealers and other registrants to better understand where examination teams will focus their efforts...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Goodwin

FINRA on Reg. BI Compliance: There is “No One-Size Fits All” Approach

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​​​​​​​FINRA recently hosted a conference call with its smaller members covering Regulation Best Interest and Form CRS compliance. FINRA’s resounding message was that there is “no one-size-fits all” approach to Reg. BI...more

Goodwin

FINRA Proposes to Publicly Identify “Restricted Firms” on BrokerCheck

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BrokerCheck is the database through which FINRA publishes licensing, registration, and disciplinary history of brokerage industry firms and their personnel. BrokerCheck does not currently specify whether a particular firm is...more

McGuireWoods LLP

FINRA Releases 2022 Report on Examination and Risk Monitoring Program

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In February 2022, the Financial Industry Regulatory Authority (FINRA) released the 2022 Report on FINRA’s Examinations and Risk Monitoring Program. This annual document aims to provide guidance to the broker-dealer industry....more

Goodwin

SEC Proposes Short Sale Disclosure Rule and Reopens Comment Period for Reporting on Securities Loans

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In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more

Cooley LLP

In most recent comments on climate disclosure, SEC drills down on materiality

Cooley LLP on

In September last year, Corp Fin posted a sample letter to companies containing illustrative comments regarding climate change disclosures, presumably designed to help companies think about and craft their climate-related...more

Goodwin

Regulation Best Interest and Form CRS: Spotlight on FINRA’s 2022 Exam and Risk Monitoring Program Report

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This is the first in a series of alerts discussing topics covered by FINRA in its 2022 Examination and Risk Monitoring Program Report (the “Report”). Here we take a look at Regulation Best Interest (“Reg. BI”) and Form CRS,...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

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In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

Goodwin

SEC Staff Provides Form CRS Observations, Expectations, and Best Practices

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On December 17, 2021, the staff of the U.S. Securities and Exchange Commission issued a statement regarding Form CRS disclosures required of SEC-registered broker-dealers and investment advisers who offer services to retail...more

Katten Muchin Rosenman LLP

SEC Enforcement Actions Highlight Regulatory Focus on Form CRS and Regulation Best Interest

The importance of investment advisers and broker-dealers to comply with obligations under Regulation Best Interest and Form CRS was highlighted by the recent filing of 27 enforcement actions by the Securities and Exchange...more

Akin Gump Strauss Hauer & Feld LLP

SEC Charges 21 Advisers for Form CRS Failures – Impact on Private Fund Managers

On July 26, 2021, 21 investment advisers entered into settlements with the Securities and Exchange Commission to resolve charges that they failed to timely file and deliver their relationship summaries on Form CRS. Penalties...more

Carlton Fields

SEC Proposes Changes to Fund Shareholder Reports, Prospectuses, SAIs, and Ads

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On August 5, the SEC proposed what it called “comprehensive modifications to the mutual fund … disclosure framework.” ...more

Goodwin

Financial Services Weekly: Amendments To SEC Proxy Solicitation Rules Approved By A 3-1 Vote

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In This Issue. The Securities and Exchange Commission (SEC) finalized amendments to its proxy solicitation rules that will modify the practices of proxy advisory firms, providing them with greater transparency and...more

Vedder Price

SEC Chairman Confirms June 30 Compliance Date for Regulation Best Interest and Form CRS

Vedder Price on

On June 15, 2020, SEC Chairman Jay Clayton released a public statement confirming the June 30, 2020 compliance date for Regulation Best Interest (Reg BI) and Form CRS. Reg BI establishes a new standard of conduct for...more

Stinson LLP

New Form CRS to be Required from Investment Advisers and Broker-Dealers Next Week

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Designed to protect retail investors from conflicts of interest, the SEC's new Regulation Best Interest, known as Reg BI, and related rules take effect on June 30, 2020. Every SEC-registered investment adviser and...more

Goodwin

U.S. Broker-Dealers and Investment Advisers: Prepare for Fast Approaching Regulation Best Interest and Form CRS Deadline

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The compliance date of June 30, 2020, is looming for U.S. broker-dealers subject to Regulation Best Interest (Reg. BI) and broker-dealers and investment advisers required to prepare and provide relationship summaries pursuant...more

Dickinson Wright

SEC Provides Guidance to Broker-Dealers and Investment Advisers Regarding Examinations for Compliance with Regulation Best...

Dickinson Wright on

On April 7, 2020, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued two risk alerts providing guidance to broker-dealers and investment advisers regarding forthcoming...more

Lowenstein Sandler LLP

SEC and FINRA Provide Reg. BI and Form CRS Guidance as the Implementation Date Approaches

Lowenstein Sandler LLP on

What You Need To Know: -The implementation date for Reg. BI and Form CRS remains June 30, 2020. -The SEC’s initial compliance review will be focused on “good-faith efforts.” Firms should make good faith efforts to implement...more

Polsinelli

SEC Announces Examination Priorities for Regulation Best Interest and Form CRS

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On June 5, 2019, the Securities and Exchange Commission (“SEC”) adopted Regulation Best Interest (“Regulation Best Interest” or “Reg BI”), which establishes a new standard of conduct under the Securities Exchange Act of 1934...more

Dorsey & Whitney LLP

OCIE, Form CRS and Inspections

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Inspections for compliance with Form CRS and its rules will begin after the June 30, 2020 filing date, according to an OCIE Risk Alert dated April 7, 2020. The Alert identifies key areas the staff will be examining regarding...more

Faegre Drinker Biddle & Reath LLP

The SEC Trading and Markets Reg BI FAQ and the SEC’s and FINRA’s Plans for Reg BI Exams

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

Eversheds Sutherland (US) LLP

Videocast: Asset management regulation in 2020 videocast series – The ADV season

Form ADV update season is now upon us, and as many investment advisers work toward the quickly approaching filing deadline, they will also have to grapple with a regulatory environment that is putting even more pressure on...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #23

Regulation Best Interest: SEC 2020 Examination Priorities—Examinations for Compliance With Reg BI and the Investment Adviser Interpretation - The SEC has issued its final Regulation Best Interest (Reg BI), Form CRS Rule,...more

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