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Regulatory Requirements Conflicts of Interest Securities Regulation

Hogan Lovells

SEC grants no action relief from paragraph (a)(3)(iii) of Rule 192

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The Securities and Exchange Commission has issued a no-action relief letter regarding paragraph (a)(3)(iii) of Rule 192 under the Securities Act of 1933, as amended. Rule 192, finalized in January 2024, implements Section 621...more

Morgan Lewis

SEC Staff Greenlights Information Barriers as Alternative Approach to Rule 192 Compliance

Morgan Lewis on

The staff of the US Securities and Exchange Commission’s Division of Corporation Finance recently granted no-action relief for transactions under Securities Act Rule 192(a)(3)(iii) (commonly known as prong (iii)) where the...more

Woods Rogers

Real Estate Syndications: Legal Considerations for Syndicators (and Investors)

Woods Rogers on

Real estate syndication involves pooling funds from multiple investors to finance a real estate project. While syndication can be a profitable investment strategy, it also comes with various legal considerations and potential...more

Stinson LLP

SEC Staff Posts Conflicts of Interest Guidance for Broker-Dealers and Investment Advisers

Stinson LLP on

On August 3, 2022, the Securities and Exchange Commission (SEC) staff published a Q&A-Styled Bulletin focused on conflicts of interest under the Investment Advisers Act of 1940 (Advisers Act) and Regulation Best Interest (Reg...more

Carlton Fields

SEC Pressures Advisers on Undisclosed Conflicts

Carlton Fields on

We are actively looking for circumstances where an adviser is financially conflicted by incentives that could affect investment recommendations to clients. ... And I will tell you: the more we look, the more undisclosed or...more

Rumberger | Kirk

Minimizing Liability Under the SEC’s Reg-BI

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Litigation Risks Posed by the SEC’s Regulation Best Interest - Pete Tepley and Meredith Lees highlight litigation risks posed by the SEC’s Regulation Best Interest (Reg-BI), litigation risks that may arise from Reg-BI’s...more

UB Greensfelder LLP

Reg BI Continues To Tantalize And Confuse Both The Industry And The Regulators

UB Greensfelder LLP on

My young boys will sometimes chase me around the house, catch me, and yell “gotcha” as they drag me off to their pretend jail. No matter how much I plead that I’ve done nothing wrong, I always end up in jail, despite having...more

Carlton Fields

New Chair on the Block Discusses Reconstructing the Suitability Model

Carlton Fields on

Ohio Department of Insurance Director Jillian Froment, the new chair of the Annuity Suitability Working Group (Working Group), invited regulators and interested parties to build the required standard of care foundation for...more

Robins Kaplan LLP

Robo-Advisors Have the Ability to Meet Fiduciary Standards, but Not All Do

Robins Kaplan LLP on

Have you ever considered investing your money with a robot? A new category of investment advisers known as robo-advisors are automated, low-cost services that provide investment advice via web or mobile platforms....more

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