Tag: Regulation Best Interest

Several States Coordinating Regulation Best Interest Pre-Implementation Exam Survey

While the SEC moved full force in adopting Regulation Best Interest and Form CRS, state regulators were fairly silent on what steps they would take pertaining to this topic. It seems the sleeping bear has awoken early this winter with the recent multi-state survey being sent to state-registered investment advisers. Many states are conducting a … 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

Takeaways from FINRA’s Examination Priorities 2020

The much-anticipated release of the Financial Industry Regulatory Authority, Inc. (“FINRA”) 2020 Risk Monitoring and Examination Priorities Letter occurred on January 9, 2020. Why is this annual release so important to broker-dealers? In short, it serves as a roadmap to identify compliance and supervisory topics that will underpin FINRA’s examination program as 2020 unfolds. After … Continued

10 Compliance Tips for Starting 2020 Off on the Right Foot

No rest for the weary. With the new year upon us, our attention turns to new budgets, change and planning. With renewed energy as we roll into January thaw, we worry if our compliance program is ready. To give you a leg up, here are 10 tips for investment adviser and broker-dealer compliance teams for … 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

Technology Advances Here and On the Way for Form CRS

CSS featured a strong presence at the recent 2019 BAM + Loring Ward Advisor National Conference in St. Louis, Mo. The conference, titled “In Our Element,” explored the chemistry of investment advisors’ relationships with their clients and the keys to successfully building those relationships. Within that context, CSS’s compliance presentation outlining the purpose and implementation … Continued

Early Impressions on Regulation Best Interest, Form CRS

One week after the SEC adopted Regulation Best Interest and Form CRS, a Cincinnati roundtable hosted by Fort Washington Investment Advisors, Inc. Private Funds & Regulatory Compliance Manager Andre Rickman ran through early impressions of the new rules and their accompanying Interpretive Releases with a very interested group. CSS Regulatory Compliance Expert Greg Hotaling opened … Continued

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

From Wall Street to Main Street: Update on Standard of Conduct for Investment Advisers

Retail investors are confused! They fundamentally cannot differentiate between a broker-dealer and an investment adviser. And that has the SEC concerned. So when the DOL Fiduciary Rule was overturned earlier this year, the SEC stepped into the debate with its April proposal. And that was a key topic of discussion at the recent CSS/Ascendant fall … Continued


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CSS frequently publishes blog posts which are written by our team from their observations in the field, at conferences and through experiences with compliance professionals. These posts are designed to further knowledge and share industry best practices. Topics run the gamut, including Form ADV, cybersecurity, MiFID II, position limit monitoring, technology challenges and more. Complete and submit the brief form below to receive notifications when we publish new content.


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