News & Analysis as of

Investment Adviser Form CRS

Katten Muchin Rosenman LLP

Spotlight on Investment Advisers and Broker-Dealers

On October 16, the Securities and Exchange Commission's (SEC) Division of Examinations (Division) published its examination priorities for its fiscal year 2024 (Oct. 1, 2023 - Sep. 30, 2024). The Division noted that the...more

Goodwin

SEC EXAMS Division Announces 2024 Priorities Ahead of Schedule

Goodwin on

On October 16, 2023, the SEC’s Division of Examinations (EXAMS) published its exam priorities for 2024. The timing is notable, with the release coming several months ahead of the typical timeline and only eight months after...more

Goodwin

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

Goodwin on

​​​​​​​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

Mayer Brown Free Writings + Perspectives

US Securities and Exchange Commission Division of Examinations 2022 Exam Priorities

On March 30, 2022, the Division of Examinations of the US Securities and Exchange Commission (the “Division” and “SEC,” respectively) announced its examination priorities for 2022. This year’s priorities specifically focus...more

Goodwin

SEC Examinations Division Publishes 2022 Priorities

Goodwin on

The SEC Division of Examinations recently published its list of priorities for 2022. While it was a bit late compared to a typical year, the priorities letter provides a roadmap for firms to better understand where the...more

Ballard Spahr LLP

Private Funds, ‘Greenwashing,’ and Crypto-Assets are Among SEC’s Top Examination Priorities in 2022

Ballard Spahr LLP on

Summary - The U.S. Securities and Exchange Commission this week published its 2022 Examination Priorities report. This year, the SEC’s Division of Examinations plans to prioritize scrutiny of Private Funds; Environmental,...more

Goodwin

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

Goodwin on

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

SEC Penalizes 12 Additional BDs and IAs with CRS Failures

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On February 15, 2022, the SEC announced settlements with 12 broker-dealers and investment advisers for failing to satisfy their Form CRS obligations. These settlements come on the heels of 27 settlements last year for similar...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

Goodwin

SEC Charges 27 Firms with Form CRS Failures

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Word to the wise: when a regulator kindly reminds you on multiple occasions that you need to comply with its rules, you should probably heed those warnings. On July 26, 2021, the SEC announced settlements with 21 investment...more

BCLP

Heads Up! Your Form CRS Grace Period Has Ended: The SEC Drops the Hammer on 27 Firms for Compliance Failures with Form CRS Filing...

BCLP on

In case you were wondering if you can still push off finalizing your Form CRS filing, posting it on your website and delivering it to clients, the SEC has read your mind and answered loudly: no more! On Monday, the SEC...more

Kilpatrick

SEC Assesses Nearly $1 Million in Fines for RIAs and BDs’ Failure to Deliver Form CRS

Kilpatrick on

Yesterday, the U.S. Securities and Exchange Commission (“SEC”) announced that it has entered final administrative orders against 21 registered investment advisers (“RIAs”) and six broker-dealers (“BDs”) for failing to file or...more

Kilpatrick

Insights into the States' 2021 BD Examination, Enforcement Priorities

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Putting Teeth on Reg BI (to take a bite out of complex products sales), Protecting Seniors (from romance scams, affinity frauds, and rogue POAs), Scrutinizing Bank-Based Reps, DBAs, and Remote Supervision, and the beginning...more

Kilpatrick

SEC Division of Examinations Releases 2021 Examination Priorities

Kilpatrick on

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

Lowenstein Sandler LLP

2020 and Q1 2021 Developments And Annual Compliance Checklists

Summaries of recent legislative and regulatory developments with respect to: •The SEC’s Examination Priorities for 2021- •The SEC’s Focus on Digital Asset Securities- •The SEC’s New Marketing Rule... ...more

Dechert LLP

SEC Division of Examinations Releases 2021 Examination Priorities

Dechert LLP on

The Securities and Exchange Commission’s Division of Examinations (EXAMS) published its report on 2021 Examination Priorities on March 3, 2021. The 2021 Examination Priorities cover eight broad topics: - The protection...more

Bressler, Amery & Ross, P.C.

Maxine Waters Presses Biden to Rescind Reg BI

President-Elect Joe Biden is quickly learning that the line of people seeking regulatory reform in the wake of the Trump administration's regulatory free-for-all is getting longer all the time. At the front of the line is...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

Stinson LLP

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

Stinson LLP on

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

Polsinelli

No Extension for You - June 30 Compliance Date for Regulation Best Interest Confirmed by SEC

Polsinelli on

On June 15, Jay Clayton, the Chairman of the U.S. Securities and Exchange Commission (“SEC”) re-confirmed there will be no delay in the compliance date for Regulation Best Interest and Form CRS. In the statement, Chairman...more

Eversheds Sutherland (US) LLP

Considerations as Regulation Best Interest and Form CRS approach June 30th compliance date

The compliance date for two rules adopted by the US Securities and Exchange Commission (SEC) last year, Regulation Best Interest (Reg BI) and the Form CRS Relationship Summary (Form CRS) is rapidly approaching for...more

Goodwin

U.S. SEC Chairman Confirms June 30th Deadline and Areas of Focus for Regulation Best Interest and Form CRS

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In a public statement issued on June 15, 2020, U.S. Securities and Exchange Commission (SEC) Chairman Clayton confirmed the June 30, 2020, deadlines for compliance with Regulation Best Interest (Reg. BI) and the Form CRS...more

Foley Hoag LLP

Form CRS Due Date Reminder

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In accordance with SEC rules, all registered investment advisers with clients that are “retail investors” are required to file Part 3 of Form ADV (Form CRS) with the SEC, and deliver a current Form CRS to clients that are...more

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