Bob has over 25 years of experience in the financial services industry. He has served as in-house counsel for Nationwide Financial Services, Inc., an affiliate of Nationwide Insurance Company, and BISYS Fund Services, a mutual fund administrator and product distributor. At Nationwide, he managed a practice group that supported Nationwide-affiliated broker-dealers and provided legal support for Nationwide insurance agents. At BISYS, he provided legal support for BISYS mutual fund clients, including the preparation and review of mutual fund registration statements, the review of advertising and sales literature and the preparation of board meeting agendas, resolutions and minutes. Prior to serving in these in-house counsel roles, Bob held the position of Attorney Adviser in the Investment Management Division of the SEC.
- Provides advice on broker-dealer, investment adviser and insurance agency compliance and supervision issues
- Drafted Compliance Manuals for SEC-registered investment advisors
- Drafted Compliance and Supervisory Policies and Procedures governing electronic communications for a large, independent broker-dealer
- Drafted firm brochures and firm brochure supplements for SEC-registered and state-registered investment advisors
- Provides comprehensive guidance and assistance to clients preparing to comply with the Department of Labor Fiduciary Rule. This includes: review and assessment of current retirement accounts; assessment of potential impact on client’s retirement business, including but not limited to compensation structure, need to rely upon Best Interest Contract Exemption, revisions to compliance and supervisory policies and procedures, product offerings, and technology platform; best practice recommendations; and the implementation process
- Conducted branch office examinations for a large independent broker-dealer
- Responsible for overseeing the filing of applications for the approval of changes in ownership of broker-dealer clients pursuant to NASD Rule 1017
- Provided advice concerning a change of the broker-dealer of record for mutual fund accounts and variable insurance product accounts held at the issuer in accordance with FINRA guidelines
- Instrumental in the development of compliance and supervisory policies and procedures for an insurance general agency that conducts life insurance and annuity business in all 50 states
- Reviewed mutual fund advertising and sales literature
- Conducted legal and compliance training courses for mutual fund clients
- Drafted and reviewed selling agreements for mutual fund distributors, variable insurance product distributors and retail broker-dealers
- Participated in the development and implementation of a comprehensive compliance program for insurance company separate accounts in accordance with Rule 38a-1 under the Investment Company Act of 1940
- Managing Counsel for Nationwide Financial Services, Inc.
- Vice President and Senior Counsel for BISYS Fund Services
- Attorney Adviser, U.S. Securities and Exchange Commission, Division of Investment Management, Office of Disclosure Review
- Attorney, Internal Revenue Service, Office of Chief Counsel, Corporation Tax Division
Education, Accolades and Industry Commitments
- Master of Laws in Taxation, Georgetown University
- Juris Doctor, Nova Southeastern University
- Master of Business Administration (Finance), University of Miami
- B.a., Government, Florida State University
- Member, State Bar of Florida
Publications and Presentations
Passage of the Senior Safe Act Will Provide Protection for Senior Investors – Oyster Blog Post, June 1, 2018
SEC Fiduciary Standards Update – Oyster Blog Post, April 19, 2018
State Enforcement Action Has Department of Labor Fiduciary Rule Implications – Oyster Blog Post, March 6, 2018
Webinar: The Countdown Is On – What’s Your DOL Game Plan? – May 10, 2017
The SECS 2017 Priorities: What They Are and What Compliance Professionals Need to Know– NSCP Currents, February, 2017.
Webinar: Anatomy of a Risk Assessment: Preparing for the DOL Fiduciary Rule Change – August 31, 2016.
The SEC’s ReTIRE Initiative: An Examination Initiative Focused on Products and Services Provided to Retail Investors Saving for Retirement – Bob Tuch – Practical Compliance & Risk Management for the Securities Industry – Wolters Kluwer, Vol. 9, No. 1, January/February 2016.
Variable Annuity Suitability – Are Your Representatives Making Suitable Product Recommendations? – Oyster Blog Post, August 24, 2015
“Compliance Challenges for Dually-Registered Firms” – Bob Tuch – Practical Compliance & Risk Management for the Securities Industry – Wolters Kluwer
Compliance Challenges for Dually-Registered Firms – Oyster Blog Post, March 26, 2015