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SEC Turns Up Heat on Share Class Selection Disclosure, Now Focusing on Other Forms of Compensation

Compliance and Regulatory Alerts  |  10-03-19

SEC Turns Up Heat on Share Class Selection Disclosure, Now Focusing on Other Forms of Compensation

The SEC Enforcement Division is continuing to concentrate on firms that did not self-report by the deadline of the SEC’s Share Class Selection Disclosure Initiative, and is now focusing on revenue-sharing payments and other forms of representative compensation or cost offsets. Bates takes a look at recent SEC actions and settlements with comments and recommendations by Securities Litigation and Regulatory Enforcement Managing Director Alex Russell.

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Hank Sanchez Speaking at SIFMA C&L New York Regional and 2019 NSCP National Conference

Bates News, Events  |  10-01-19

Hank Sanchez Speaking at SIFMA C&L New York Regional and 2019 NSCP National Conference

Bates Managing Director and Expert Consultant Hank Sanchez will be speaking at the SIFMA C&L New York Regional Seminar October 22nd and at the 2019 NSCP National Conference October 23rd.

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Bates Managing Director Robert Lavigne Quoted in Investment News Article

Bates News  |  09-27-19

Bates Managing Director Robert Lavigne Quoted in Investment News Article

Bates Compliance Managing Director Robert Lavigne is quoted in a new article from Investment News.

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NASAA Enforcement Report Shows Increased Investment Adviser Actions, Focus on Crypto, Senior Fraud

Bates Research  |  09-26-19

NASAA Enforcement Report Shows Increased Investment Adviser Actions, Focus on Crypto, Senior Fraud

In its 2019 annual enforcement report, the North American Securities Administrators Association ("NASAA") highlighted statistics from its 2018 state enforcement activities. The data show that the state securities regulators secured more than $1 billion in restitution and fines as well as significant criminal penalties. The report also notes that state regulators nearly doubled enforcement actions against investment adviser firms. Here, Bates Research takes a closer look.

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Bates Welcomes Our Newest Experts and Consultants

Bates News  |  09-23-19

Bates Welcomes Our Newest Experts and Consultants

Bates is proud to introduce our newest experts and consultants: Donna Bartlett, Frank Giorgio, Richard Rogoff and William Webb.

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OCIE Issues Risk Alert on Principal Trading and Cross Transaction Compliance Obligations

Compliance and Regulatory Alerts  |  09-23-19

OCIE Issues Risk Alert on Principal Trading and Cross Transaction Compliance Obligations

The SEC Office of Compliance, Inspections and Examinations (OCIE) issued a Risk Alert to remind investment advisers of their compliance obligations for principal trading and agency cross transactions involving clients. Specifically, OCIE alerted investment advisers of their responsibility to comply with disclosure and consent requirements under the Investment Advisers Act and that, except for specific circumstances related to cross trades, the rules require compliance on a “transaction-by-transaction basis – blanket disclosure and consent are not permitted.”

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FINRA Requests Feedback on Senior Financial Protection Rules

Bates Research  |  09-19-19

FINRA Requests Feedback on Senior Financial Protection Rules

In a new Regulatory Notice, FINRA is asking its members a series of questions about the utility of rules and processes to curb financial exploitation of senior investors. According to FINRA, the rules under review provide a way for member firms to deal with situations where there is “a reasonable basis to believe that financial exploitation has occurred, is occurring, has been attempted or will be attempted.”

Bates Research closely follows regulatory and enforcement developments on senior financial fraud. In this article, we recap those rules and consider the questions posed by FINRA in its latest Notice.

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States Sue SEC in Latest Challenge to Reg BI

Bates Research  |  09-12-19

States Sue SEC in Latest Challenge to Reg BI

The SEC’s adoption of the Regulation Best Interest (“Reg BI”) package in June was a defining moment in the long-running debate over the standard of care for broker-dealers and investment advisers. It triggered compliance schedules and required registered broker-dealers and advisory firms to develop internal policies and procedures in order to satisfy the new standards. The passage of Reg BI, however, did not quell the ongoing controversies over the appropriateness and adequacy of standards and investor protections. This week, Reg BI suffered another state challenge, this time in the form of a lawsuit filed against the SEC by seven State Attorneys General. Bates Research takes a closer look.

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Bates Managing Director Hank Sanchez Publishes New Reg BI Article in NSCP Currents

Bates News  |  09-05-19

Bates Managing Director Hank Sanchez Publishes New Reg BI Article in NSCP Currents

Bates is proud to share the publication of “With Regulation BI, Are FINRA Rules 2010 and 2111 Dead?” by Managing Director and Expert Consultant Hank Sanchez, Esq. Look for Hank at the 2019 NSCP National Conference, October 21-23 at the Hilton Baltimore. 

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Bates Expands Financial Crimes Roster with Managing Director Dennis Greenberg

Bates News  |  09-04-19

Bates Expands Financial Crimes Roster with Managing Director Dennis Greenberg

Bates Group welcomes Dennis Greenberg as the new Managing Director of Business Development for Bates AML and Financial Crimes.

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