Reg BI Implementation Deadline!

June 30, 2020 is is implementation deadline for Reg BI Getting help with the process of conflict identification, mitigation and disclosure, as well as updating policies and procedures will provide your firm with an objective view of conflicts and allows your team to continue meeting its regular compliance obligations with limited disruption. Our team of former… READ MORE

SEC Examinations that Focus on Compliance with Form CRS Requirements

Form CRS and its related rules (“Form CRS”) require SEC-registered broker-dealers and investment advisers to deliver to retail investors a brief customer or client relationship summary (relationship summary) that provides information about the firm.  The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert to provide firms with information about the… READ MORE

SIFMA Regulation Best Interest Vendor Forum

isBy June 30, 2020, registered broker-dealers must comply with Regulation Best Interest; and broker-dealers and investment advisers registered with the SEC must prepare, file, and deliver to retail investors, a new customer relationship summary (Form CRS). To complement SIFMA’s Reg BI Implementation Guide, this event will provide attendees an overview of the implementation considerations, and… 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

SEC Publishes Form CRS FAQs

As the effective dates for Reg BI approach, we are starting to see more information and activity around certain aspects of the rule.  This includes some welcome FAQ’s around Form CRS. On November 26, 2019 the staff of the Division of Investment Management and the Division of Trading and Markets released FAQs to help registrants prepare… READ MORE

Compliance Procrastinators – With 2020 Compensation Planning Heating Up- Now is the Time to Make Sure Reg BI is Fully Understood

Reg BI has made some decisions very easy. The rule requires firms to “identify and eliminate sales contests, sales quotas, bonuses, and non-cash compensation that are based on the sale of specific securities or specific types of securities within a limited period of time.” With compensation planning for 2020 discussions typically heating up in the fall,… READ MORE