On 20 May 2019, the FCA published findings from its multi-firm review into the supervision by principal firms of their appointed representatives (“ARs“) in the investment management sector (“Investment Management Sector...more
At the NAIC Fall 2018 National Meeting, state regulators continued plowing through the Suitability in Annuity Transactions Model Regulation (Model 275) (Suitability Model)....more
The SEC, on June 5, announced that it would be exploring “modernization of the design, delivery and content of fund disclosures” in order “to improve the investor experience and help investors make more informed investment...more
On June 28, the SEC proposed new rule 6c-11 to allow open-end exchange-traded funds that satisfy certain conditions to operate without obtaining an SEC exemptive order. The proposed rule would apply to open-end ETFs, but...more
At the 2018 NAIC Summer National Meeting, regulators continued their efforts to define the standard of care that applies to recommendations. This subject was discussed at both the Annuity Suitability (A) Working Group...more
On July 24, in preparation for its August 4 meeting at the NAIC 2018 Summer National Meeting, the Annuity Suitability (A) Working Group (the “Suitability WG”) peddled fast and released a working draft of proposed revisions...more
On July 18, New York's Department of Financial Services (the "NY DFS") issued the final version of its Suitability and Best Interests in Life Insurance and Annuity Transactions Regulation (the "Suitability and Best Interest...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
U.S. Financial Industry Developments - LIBOR "Transition" - While there is a way to go until the end of 2021 when panel banks will no longer be required to provide LIBOR quotes to the FCA, we expect to see more and more...more
During two weeks in April, two different courts — the Second Circuit and the New Jersey Superior Court — considered nearly identical allegations regarding variable products and reached diametrically opposed conclusions about...more