Blog
The DOL’s Fiduciary Rule Transition Period Extended 18 Months
As you may recall, the Fiduciary Rule’s BIC Exemption and Principal Transaction Exemption became applicable on June 9, 2017, with transition relief through January 1, 2018. However, recently the Department of Labor announced the delay of the second implementation of the Fiduciary Rule, amending it from January 1, 2018 to [...]
Regulation D Exemptions
Regulation D, established by the Securities and Exchange Commission, provides exemptions that allows companies to raise capital through the sale of unregistered securities. Under Regulation D, companies can avoid the costs associated with a public offering. Although companies are not required to register with the SEC under Regulation D, they [...]
Change to Definition of Qualified Client
The Securities and Exchange Commission (“SEC”) recently announced an upcoming change to the definition of “qualified client” as defined in Rule 205-3 under the Investment Advisers Act of 1940 (“Advisers Act”) that will become effective August 15, 2016. This applies to any Registered Investment Adviser (“RIA” or “Investment Adviser”) that [...]
FINRA Rule 2273-Recruitment Practices
FINRA has long been concerned with practices used by broker-dealers and their newly registered representatives to convince clients to transfer accounts from the representative’s old firm as well as the fees that are sometimes associated with such transfers. To address this concern, FINRA Rule 2273 requires broker-dealers to deliver an [...]
New Anti-Money Laundering Program Requirements
Recently, the Financial Crimes Enforcement Network (“FinCEN”) adopted a final rule on Customer Due Diligence (“CDD”) Requirements for Financial Institutions. As a result, firms will be required to address the new requirements within their Anti-Money Laundering (AML) programs. Firms must be in compliance with its provisions by May 11, 2018. [...]
The SEC’s Priorities in 2018
Recently, the Securities and Exchange Commission’s Enforcement Division released their annual report detailing its priorities for 2018. The department will be guided by 5 principles: Focus on the Main Street Investor, Focus on Individual Accountability, Keep Pace with Technological Change, Impose Sanctions that Most Effectively Further Enforcement Goals, and Constantly [...]