Focus Perspective: Examination Goals & More

Examination Goals Fiscal year 2018 is over, and 2019 has begun. We don’t know if the SEC’s examination staff has met the goal of 2,120 examinations of registered investment advisers (“RIAs”) or not, roughly 15% of the number of SEC … Read More ›

Focus Perspective: A Busy Month

Standard of Conduct for Investment Advisers The SEC continued to receive comments, with most of the later comments (after the cut-off date) from organizations that presumably gathered suggestions from their members and/or constituents: Members of Congress, AARP, NASAA, ABA, and … Read More ›

Follow Up: Proposed Standards of Conduct for BDs and IAs

First, an update on the proposed Standards of Conduct for Broker-Dealers and Investment Advisers. Several thousand comments were received by the announced end of the comment period, and the SEC’s website is reflecting comments received after the comment period closed. … Read More ›

Focus Perspective: National Exam Program Risk Alerts

On July 11, 2018, the SEC’s Office of Compliance and Examinations (“OCIE”) issued the third Risk Alert for the 2018 fiscal year, “Compliance Issues Related to Best Execution by Investment Advisers,” following “Overview of the Most Frequent Advisory Fee and … Read More ›

The SEC’s Four-Year Goals

On June 19, 2018, the SEC published a draft strategic plan for comment that outlined the Commission’s goals for the next four fiscal years, 2018 through 2022, and asked the public for comments on those goals. The core principles that … Read More ›

Focus Perspective: SEC’s Proposed Fiduciary Rule

Last month we talked about the SEC’s proposed Fiduciary Rule (as compared to the DOL’s proposed Fiduciary Rule), but since the proposals do not place a fiduciary obligation on the broker-dealer, I like SEC Commissioner Hester Peirce’s reference to a … Read More ›