Reg BI and Form CRS: Compliance Still Expected by June 30, 2020

Reg BI Update – SEC Warns that “firms should continue to make good faith efforts around operational matters to ensure compliance by June 30, 2020”   With so many firms changing how they serve their retail clients during the COVID-19 outbreak, the SEC issued a Public Statement on April 2nd related to Regulation Best Interest… READ MORE

Form ADV and Form PF Relief: Understanding the SEC’s Exemptive Order

The SEC provided an exemptive order this week in response to the COVID-19 event.  In limited circumstances, Investment Advisors and Exempt Reporting Advisors will have an additional 45 days from the original deadline to complete and submit their annual filings or material changes. Procrastinators need to understand that there are specific circumstances requirements to meet… READ MORE

2020 SEC Examination Priorities Released

The Office of Compliance Inspections and Examinations of the Securities and Exchange Commission (OCIE) released their 2020 Examination Priorities Letter on January 7, 2020.   While every area is important, when you read this in context of prior releases, most of the priorities are the same; however, there are some evolving priorities as well. Regulation Best… READ MORE

Is Your Compensation Structure Ready for Reg BI?

If you’re a broker-dealer that is just beginning your Reg BI implementation process, you should quickly review your compensation plan to understand what changes (if any) need to be made to your payout structure to be Reg BI-compliant.  Make sure your payroll team is thinking about how a mid-year amendment is going to work if… READ MORE

Digital Assets – Where Are We Now?

Last week, JP Morgan announced the launch of “JPM Coin.”  We thought it would be good to recap our posts over the past year on the topic of cryptocurrencies and coin offerings and update you on the current state of this market.   As 2018 began, the market capitalization for cryptocurrencies and other digital assets had reportedly exceeded… READ MORE