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Regulation Best Interest

Seward & Kissel LLP

Financial Services Firm Affiliates Settle Five SEC Enforcement Actions for Allegedly Misleading Customers and Failing to Act in...

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Who may be interested: Registered Investment Companies; Registered Investment Advisers; Broker Dealers; Compliance Officers; Boards of Directors - Quick Take: The SEC recently settled five separate enforcement proceedings...more

Paul Hastings LLP

SEC Examination Priorities Signal Capital Markets Enforcement

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The Securities and Exchange Commission’s Division of Examinations recently released its 2025 priorities. These identify several new or emerging areas of focus that could be precursors to enforcement actions, such as the use...more

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

Foley & Lardner LLP

SEC’s Division of Examinations Releases Priorities for Fiscal Year 2025

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Last week, on October 21, 2024, the SEC’s Division of Examinations released its Examination Priorities report for fiscal year 2025 (found here). As we have seen with past annual reports, the Division intends to cover a broad...more

Cozen O'Connor

Navigating the Future: Key Takeaways & Insights from the 2024 Securities Enforcement Forum Central

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One of the concerns following the Supreme Court’s ruling in SEC v. Jarkesy was that other agencies may face similar collateral attacks to its administrative proceedings. While the full impact of Jarkesy remains an open...more

Mayer Brown Free Writings + Perspectives

FINRA Sanctions Broker-Dealer for Failure to Supervise Recommendations of Structured Notes

A broker-dealer failed to reasonably supervise its registered representatives when making recommendations of certain variable rate structured products (“VRSPs”), including fixed to floating rate steepeners and other variable...more

Morgan Lewis

Securities Enforcement Roundup – September 2024

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In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments and cases from September 2024. In September 2024 (the last month of the US Securities and Exchange Commission’s...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (49): Recommendations to Transfer IRAs (NAIC)

The stay of the effective dates of the amended fiduciary regulation and amended exemptions means that the “old” DOL fiduciary regulation (the 5-part test) and the existing exemptions continue in effect indefinitely....more

Mayer Brown Free Writings + Perspectives

Broker-Dealer’s Failure to Comply with Regulation Best Interest’s Compliance Obligation is a Willful Violation of the General...

A broker-dealer (the “Dealer”) entered into a cease-and-desist order with the Securities and Exchange Commission for failing to maintain and enforce written policies and procedures reasonably designed to achieve compliance...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (48): Recommendations to Transfer IRAs (DOL)

The stay of the effective dates of the amended fiduciary regulation and amended exemptions means that the “old” DOL fiduciary regulation (the 5-part test) and the existing exemptions continue in effect indefinitely....more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (47): Recommendations to Transfer IRAs (SEC)

The stay of the effective dates of the amended fiduciary regulation and amended exemptions means that the “old” DOL fiduciary regulation (the 5-part test) and the existing exemptions continue in effect indefinitely. As a...more

Orrick, Herrington & Sutcliffe LLP

FINRA charges member firm with Regulation Best Interest violations

On August 5, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) against a member firm for three alleged violations related to the failure to maintain policies and procedures and supervisory systems in compliance...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (44): The Regulation and Exemptions are Stayed (4)—What Remains?

The DOL’s fiduciary regulation was scheduled to become effective this September 23. The exemptions were scheduled to become partially effective this September 23 and fully effective September 23, 2025....more

Orrick, Herrington & Sutcliffe LLP

FINRA accepts AWC regarding Regulation Best Interest/Form CRS

On July 19, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) from a member firm to resolve alleged Regulation Best Interest (Reg BI) violations. According to the AWC, from June 2020 to March 2023, the member...more

Mayer Brown Free Writings + Perspectives

SEC Investor Advocate Report on Objectives

The Securities and Exchange Commission’s Office of the Investor Advocate recently issued its fiscal year 2025 Report on Objectives. The Report is one of two annual reports required to be filed by the Investor Advocate with...more

Seward & Kissel LLP

Class Action Suit Filed Against Morgan Stanley Over Rates on Bank Deposit Program

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On June 14, 2024, a class action lawsuit was filed in the U.S. District Court for the Southern District of New York against Morgan Stanley alleging a breach of its fiduciary duty to customers and unjust enrichment by, among...more

SEC Compliance Consultants, Inc. (SEC³)

What Advisers Need to Know Now About Giving Rollover Advice after September 23, 2024

This article was originally published on Kitces.com, on May 15, 2024, and is available at at DoL’s Retirement Security Rule & PTE 2020-02 Amendment: What Advisers Need to Know Now about Giving Rollover Advice After September...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (33): The DOL’s Final PTE 84-24

On April 25, 2024, the Department of Labor published its final regulation defining fiduciary status for investment advice and the related exemptions—PTE 2020-02 and 84-24. The exemptions provide relief from prohibited...more

Goodwin

FINRA Proposes to Add ‘Knowledgeable Employees’ to Category of Persons Who May Receive Projections and Targeted Returns Under Rule...

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This amendment builds on FINRA’s recent willingness to relax the prohibition on the use of projections and targeted returns in the marketing materials broker-dealers deliver to institutional investors and qualified...more

Goldberg Segalla

Brokers Better Be Ready for Bitcoin ETFs

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KEY TAKEAWAYS - The U.S. Securities and Exchange Commission (SEC) has approved the first spot Bitcoin ETFs, also known as an exchange-traded product (ETP.) With the SEC now permitting spot Bitcoin ETFs, brokers must become...more

WilmerHale

FINRA’s 2024 Annual Regulatory Oversight Report: What Broker-Dealers Need to Know

WilmerHale on

On January 9, 2024, the Financial Industry Regulatory Authority published its 2024 FINRA Annual Regulatory Oversight Report. Previously titled Report on FINRA’s Examination and Risk Monitoring Program, the Report is released...more

Carlton Fields

NASAA Report on BD Compliance With Reg BI: Finds Progress, but Specifies Work To Be Done

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A September report of the North American Securities Administrators Association (NASAA) on broker-dealer compliance with the SEC’s Regulation Best Interest (Reg BI) finds...more

Procopio, Cory, Hargreaves & Savitch LLP

What to Expect from the SEC’s Examination Focus in 2024

Investment advisers, broker-dealers, fund managers and other financial professionals could be impacted in 2024 by the U.S. Securities and Exchange Commission’s (SEC) continued focus on upcoming examinations. The SEC unveiled...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (10): What is An Investment? (Part 2)

The U.S. Department of Labor has released its package of proposed changes to the regulation defining nondiscretionary fiduciary advice and to the exemptions for conflicts and compensation for investment recommendations to...more

Bracewell LLP

FINRA Facts and Trends: December 2023

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Welcome to the latest issue of Bracewell’s FINRA Facts and Trends, a monthly newsletter devoted to condensing and digesting recent FINRA developments in the areas of enforcement, regulation and dispute resolution. This month,...more

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