News & Analysis as of

Form CRS Office of Compliance Inspections and Examinations

Kilpatrick

SEC Division of Examinations Releases 2021 Examination Priorities

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Each year, the SEC’s Division of Examinations (f.k.a. OCIE) (the “Division”) releases its priorities for the upcoming year, providing SEC registrants with a helpful tool to assist in managing, reviewing, and updating their...more

Faegre Drinker Biddle & Reath LLP

SEC Roundtable on Reg BI and Form CRS

The U.S. Securities and Exchange Commission (SEC) hosted a virtual roundtable in late October to discuss the Regulation Best Interest (Reg BI) and Form CRS. With a few months of observations from examinations since the June...more

Faegre Drinker Biddle & Reath LLP

Have No Fear, Reg BI Is Finally Here

All things come to those who wait … even Regulation Best Interest (colloquially known as Reg BI). In what now feels like a lifetime since the Securities and Exchange Commission (SEC) adopted it (believe it or not, it was only...more

Troutman Pepper

Investment Management Update - June 2020

Troutman Pepper on

SEC Grants Additional COVID-19 Relief to Business Development Companies - On April 8, the SEC issued an order granting relief to business development companies (BDCs) by permitting BDCs to issue and sell senior securities...more

Troutman Pepper

Initial Form CRS Filings Due by June 30; Compliance Date Not Extended

Troutman Pepper on

On April 7, 2020, the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) announced that, after the initial June 30, 2020 compliance date to file Form CRS, the OCIE will conduct...more

Vedder Price

Investment Services Regulatory Update - May 2020

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New Rules, Proposed Rules, Guidance and Alerts - PROPOSED RULES - SEC Proposes New Fair Valuation Framework for Registered Funds - Under the Investment Company Act of 1940, securities held by a fund for which...more

Vedder Price

Form CRS Update – OCIE Risk Alert on Initial Examinations

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On April 7, 2020, the Securities and Exchange Commission’s (the “SEC” or the “Staff”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide SEC-registered broker-dealers and investment...more

Kramer Levin Naftalis & Frankel LLP

OCIE Issues Risk Alert on Form CRS Compliance

With the compliance date of June 30, 2020 approaching for Form CRS and its related rules, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) recently issued a risk...more

K&L Gates LLP

OCIE Issues Guidance for Examinations of Regulation Best Interest and Form CRS

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The June 30 deadline for compliance with Regulation Best Interest [1] and Form CRS [2] presents new compliance obligations for broker-dealers and investment advisers engaging in a retail business. In anticipation of this...more

Faegre Drinker Biddle & Reath LLP

SEC Examination Guidelines and FAQs on Form CRS

The SEC has issued guidance addressing the Form CRS. The first is a Risk Alert from the Office of Compliance Inspections and Examinations (OCIE) indicating that OCIE will be looking for good faith compliance when it conducts...more

Proskauer Rose LLP

OCIE Issues Risk Alert in Connection with Upcoming Deadline for New Form CRS

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On April 7, 2020, the Securities and Exchange Commission's (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a risk alert in connection with upcoming examinations that will focus on compliance with Form...more

Polsinelli

SEC Announces Examination Priorities for Regulation Best Interest and Form CRS

Polsinelli on

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

Pillsbury Winthrop Shaw Pittman LLP

Despite COVID-19 Challenges, No Extension of Form CRS Compliance Date for Investment Advisers

On April 7, 2020, the staff of the Office of Compliance Inspections and Examinations (OCIE) issued a risk alert (Alert) informing investment advisory firms of the potential areas of focus for Form CRS-related examinations. In...more

Dechert LLP

OCIE Publishes Risk Alerts Providing Advance Information Regarding Inspections for Compliance with Regulation Best Interest and...

Dechert LLP on

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations issued two Risk Alerts (Risk Alerts)1 on April 7, 2020, identifying the scope and content of OCIE’s initial examinations following the...more

Mintz - Securities & Capital Markets...

FINRA Agrees with SEC Regarding Enforcement of Regulation BI in Light of COVID-19

On April 7, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published two Risk Alerts for Regulation BI and the corresponding Customer Relationship Summary Form (Form CRS). The Risk Alerts outline the...more

Morrison & Foerster LLP

SEC Maintains Focus On Implementing Regulations BI And Form CRS

Last year, the Securities and Exchange Commission (“SEC”) adopted measures intended to enhance the protection of retail investors who engage financial professionals to assist them with investments. Regulation Best Interest...more

Kilpatrick

OCIE Issues Risk Alerts Previewing Initial Exams' Focus on Compliance with Reg BI, Form CRS

Kilpatrick on

On April 7, 2020, the SEC's Office of Compliance Inspections and Examinations ("OCIE") issued two risk alerts regarding the expected scope and content of initial examinations for compliance with Form CRS and Regulation Best...more

Faegre Drinker Biddle & Reath LLP

SEC Issues Exam Guidance and New FAQs for Form CRS Compliance

The Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) will be looking for good faith compliance when it conducts examinations of Form CRS after the June 30, 2020 compliance...more

Goodwin

Financial Services Weekly Roundup: The SBA’s New Paycheck Protection Program

Goodwin on

Paycheck Protection Problems. In last week’s Roundup, we discussed the initial guidance issued by the U.S. Department of the Treasury (Treasury) and the Small Business Administration (SBA) on the implementation of the...more

Burr & Forman

OCIE Exam Guidance on Reg. BI & Form CRS

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On April 2, Chair Clayton said the SEC would hold firm on the June 30 compliance deadline for Regulation Best Interest (“Reg. BI”) and Form CRS, but suggested early examinations might focus more on compliance efforts than...more

Dorsey & Whitney LLP

OCIE, Form CRS and Inspections

Dorsey & Whitney LLP on

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

McGuireWoods LLP

SEC Issues Regulation Best Interest Risk Alerts, After Declining to Delay Compliance Date

McGuireWoods LLP on

As McGuireWoods reported in an April 6, 2020, legal alert, the U.S. Securities and Exchange Commission (SEC) has indicated that it will not be delaying the June 30, 2020, compliance deadline for Regulation Best Interest (Reg...more

UB Greensfelder LLP

OCIE Offers Reg BI Examination “Study Guides” (But Not An Extension)

UB Greensfelder LLP on

This week OCIE issued twin alerts relating to the upcoming implementation of Reg BI. A lot of the statements are nothing new – brief repetitions of the Regulation, the four obligations, etc. None of that should be new...more

Vedder Price

Board Oversight in the Age of COVID-19: Part Three

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Part 3 of a weekly series detailing approaches that independent board members are utilizing to address coronavirus-related matters and highlighting emerging issues. Part 1 and Part 2 of the series may be accessed on our...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

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