News & Analysis as of

Regulation Best Interest Form CRS

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

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

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

Carlton Fields

FINRA Issues 2023 Report on Examination and Risk Monitoring Program

Carlton Fields on

On January 10, 2023, FINRA issued its 2023 Report on FINRA’s Examination and Risk Monitoring Program to provide “insight into findings from the recent oversight activities of FINRA’s Member Supervision, Market Regulation and...more

Burr & Forman

FINRA 2023 Exam Priorities

Burr & Forman on

Every year the Financial Institution Regulatory Authority (FINRA) issues its “Report on FINRA’s Examination and Risk Monitoring Program.” The Report covers issues noted during the prior year’s exams and topics that examiners...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

Nelson Mullins Riley & Scarborough LLP

SEC Identifies 2022 Examination Priorities

The SEC’s Division of Examinations prioritizes the examination of certain practices, products, and services that it believes present potentially heightened risks to investors. Recently, the Division released its 2022...more

McGuireWoods LLP

FINRA Releases 2022 Report on Examination and Risk Monitoring Program

McGuireWoods LLP on

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

Goodwin on

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

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

Epstein Becker & Green

FINRA Issues 2022 Report on Examination and Risk Monitoring Program – Technology among the Areas for Focus

Epstein Becker & Green on

Last week, FINRA published its 2022 Report on its Examination and Risk Monitoring Program (the “Report”), identifying key areas of focus for broker-dealer exams this year. The Report contains many of the same areas of focus...more

Carlton Fields

FINRA Issues 2022 Report on Examination and Risk Monitoring Program

Carlton Fields on

On February 9, 2022, FINRA issued the 2022 Report on FINRA's Examination and Risk Monitoring Program to provide firms with "information that may help their compliance programs." The 2022 report addresses 21 topic areas. For...more

Carlton Fields

Regulation Best Interest and Form CRS: Examinations and Enforcement Heat Up

Carlton Fields on

Not long after the SEC adopted Regulation Best Interest (Reg BI) and the related Form CRS Relationship Summary in June 2019, the SEC Office of Compliance Inspections and Examinations (now the Division of Examinations) issued...more

Groom Law Group, Chartered

Is a New Era Coming for Robo-Advice? SEC Requests Information

On August 27, 2021, the Securities and Exchange Commission (“SEC”) issued its Request for Information (“RFI”) on matters related to broker-dealer and advisory firm’s usage of digital engagement practices (“DEPs”), which...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

Bressler, Amery & Ross, P.C.

SIFMA C&L Virtual Forum Addresses FINRA’s 2021 Priorities for Private Client Firms

On July 20, 2021, SIFMA hosted a panel discussing key legal and regulatory issues for private client firms at SIFMA’s 2021 C&L Virtual Forum. Several key subjects were discussed by the panel, including: (1) FINRA’s 2021...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

Insights into the States' 2021 BD Examination, Enforcement Priorities

Kilpatrick on

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

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

UB Greensfelder LLP

SEC 2021 Exam Priorities

UB Greensfelder LLP on

Today, the SEC put out its 2021 Exam Priorities, available here. It is about 40 pages long and covers a lot of topics. While I encourage everyone to read through the document, here are the primary focus items for 2021: ...more

Troutman Pepper

FINRA Publishes New Annual Report on FINRA’s Examination and Risk Monitoring Program

Troutman Pepper on

Why It Matters - The 2021 Report on FINRA’s Examination and Risk Monitoring Program serves as an authoritative resource for member firms to evaluate and, where necessary, enhance their compliance programs and operations...more

Epstein Becker & Green

FINRA Issues 2021 Report on Examination and Risk Monitoring Program

The recently issued 2021 Report on FINRA’s Examination and Risk Monitoring Program (the “Report”) replaces, and combines, two previously published FINRA reports – The Report on Examination Findings and Observations as well as...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

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