Tag: Reg BI

SEC’s New Committee Begins Review of Form CRS Filings

The SEC’s Divisional Standards of Conduct Implementation Committee launched its review of Form CRS from a cross section of RIAs and BDs to assess compliance with the content and format requirements. Initial observations from the Committee have identified examples of relationship summaries that may lack certain disclosures or could be clearer or otherwise improved. The … Continued

Don’t Forget the Disclosure Obligation

Recently, the SEC announced the settlement of an enforcement case against Morgan Stanley Smith Barney (MSSB) involving charges that MSSB provided misleading information to its clients in connection with trading costs in its retail wrap fee programs. MSSB agreed to pay a $5 million penalty that will be distributed to harmed investors. The case is … Continued

New SEC Risk Alerts

The SEC today issued Risk Alerts identifying areas related to Form CRS and Regulation BI on which examiners will focus during upcoming exams. The SEC indicated in today’s Form CRS Risk Alert that RIAs need to meet content, delivery and record keeping requirements. The SEC referred RIAs to the Form CRS Adopting Release and Small … Continued

Pathway to Reg BI Compliance: Have You Started Your Conflict of Interest Assessment?

As the June 30, 2020 compliance date for the SEC’s Regulation Best Interest (“Reg BI”) draws near, broker-dealers are scrambling to design and implement a comprehensive solution to ensure compliance with Reg BI. In short, Reg BI requires that broker-dealer recommendations be in the retail client’s best interest, creates a broad disclosure obligation, and compels … Continued

Compliance Lessons Learned in 2019

Now that we are in mid-January, a few things are evident. We have likely broken one or more New Year’s resolutions, the effect of any rest over the holidays has worn off and we need to complete our annual compliance reviews for 2019 and firm up our 2020 plans. While I don’t have solid advice … Continued


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