... with investment advisers and broker-dealers. Design/Methodology/Approach The article provides legal analysis for and historical context of the requirements of the SEC’s adopted rules, Regulation Best Interest and Form CRS in addition to the two separate interpretations under the Investment Advisers Act...

... liability for broker-dealers and investment advisers, and highlights key takeaways from the SEC’s recent enforcement resolution that may be applied in establishing compliance procedures relating to internal investigations going forward. Findings The article concludes that the SEC appears to expect...

...Wendy E. Cohen; Richard D. Marshall; Allison C. Yacker; Lance A. Zinman Purpose To explain actions the US Securities and Exchange Commission (SEC) brought on August 27, 2018, against a group of affiliated investment advisers and broker-dealers for what the SEC considered misleading...

... professionals. The three proposals included: interpretation regarding the standard of conduct of investment advisers under the Investment Advisers Act of 1940; Form CRS which both registered investment advisers and registered broker-dealers would have to provide to retail investors; and proposed regulation best...

.... Licensed re-use rights only Financial Industry Regulatory Authority (FINRA) Broker-dealers Financial exploitation US Securities and Exchange Commission (SEC) Seniors and other vulnerable adults Trusted contact person (TCP) Effective February 5, 2018, Financial Industry Regulatory Authority...

...: Commissioner Hester Peirce explained her view that economic analysis should be one of the central elements of securities regulation. She also suggested that the SEC should create a separate regulatory framework for “finders” of capital, who currently must register as broker-dealers. Commissioner...

... Authority (FINRA) Seniors Broker-dealers Registered representatives Financial exploitation On March 30, 2017, the SEC approved the adoption of new FINRA Rule 2165 (Financial Exploitation of Specified Adults). (See www.finra.org/sites/default/files/Regulatory-Notice-17-11.pdf and our related blog...

...Bradley J. Bondi; Charles A. Gilman; Kimberly C. Petillo-Décossard; John J. Schuster; Sara Ortiz Purpose To explain a recent US Securities and Exchange Commission (SEC) administrative proceeding targeting a broker-dealer as part of the Commission’s continuing efforts to enforce anti-money...

.... Findings As in recent years, there is a significant overlap in priorities between the two regulators on issues of elderly investors, recidivist representatives, product suitability, and cybersecurity, among others. Practical implications Registered investment advisers and broker-dealers should note...

... describes the impact of the new “fiduciary” rule on broker-dealers, banks and other financial organizations who will, for the first time since the passage of ERISA, be subject to ERISA’s fiduciary standards and remedies when providing investment and asset management recommendations to individual retirement...

...Brian Rubin; Amy Xu Purpose To analyze how the US Securities and Exchange Commission (SEC) has sanctioned broker-dealers (BDs) and registered investment advisers (RIAs) when cybersecurity breaches have occurred and to discuss whether the SEC is imposing a strict liability approach. Design...

... adopted by the SEC for certain capital market transactions in connection with determining whether a person is a large trader. Findings The SEC extended the April 30, 2012 compliance date under Rule 13h‐1 for registered broker‐dealers by 12 months to May 1, 2013; however, broker‐dealers that are either...

..., 2012. The text of FINRA Rule 4240 is available in the online FINRA Manual. Questions concerning this Notice should be directed to: Regulation Financial markets Securities markets United States of America Credit default swaps Securities trading Broker‐dealers Record‐keeping...

.... Jason Lane can be contacted at: jason.lane@bingham.com © Emerald Group Publishing Limited 2011 Securities regulation Broker‐dealers Investment advisers Investments Advisory services Information disclosure Regulation United States of America Enforcement alleged that these actions...

... identification number (“LTID”) and provide the LTID to each US‐registered broker‐dealer through which it effects transactions in NMS securities. The Rule also requires US‐registered broker‐dealers to provide to the SEC, on request, data on large traders' transactions in NMS securities by the morning after...