Posts By: Keith Marks

SEC Adopts Regulation Best Interest, Form CRS; Also Issues Interpretive Releases on IA Fiduciary Duty and Solely Incidental Exception

By a 3-1 vote, on June 5, 2019, the SEC acted to provide a new regulatory framework to help retail, or main street, investors understand the distinctions between broker-dealers and investment advisers, particularly the standards of conduct owed by each. Opening remarks by SEC Chair Jay Clayton noted that as markets have developed over the … Continued

Regulation Best Interest, Cybersecurity Top Concerns at IAA 2019 Compliance Conference

The Investment Adviser Association (IAA) represents the interests of investment advisers in Washington D.C., and the IAA Investment Adviser Compliance Conference 2019 was a forum for the discussion of future potential rulemaking. Cybersecurity and Fiduciary Rule considerations were headline topics, with custody and marketing right behind. The following is a summary of key issues discussed … Continued

Pennsylvania Sounds Warning Bell Over Client Credentials and Custody

The Pennsylvania Department of Banking and Securities (PDOBS) has indicated in recent guidance two concerns related to investment advisers using client credentials to access a custodial account(s). In the letter dated September 25, 2018, PDOBS indicates that the use of client credentials may create custody and is considered to be a dishonest and unethical practice. … Continued


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