Compliance and Regulatory Alerts | 04-13-18
Comments must be submitted by April 27, 2018 on a FINRA proposal to consolidate rules on outside business activities of registered persons (Rules 3270 & 3280). The proposal contains a number of amendments intended “to reduce unnecessary burdens while strengthening investor protections.”
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Compliance and Regulatory Alerts | 03-09-18
The SEC Division of Enforcement announced a "Share Class Select Disclosure Initiative" intended to protect and reimburse investors from an adviser’s conflict of interest. The new initiative offers an incentive to advisers and related individuals and entities to review and potentially self-report conflicts of interest, as they relate to the adviser’s collection of 12b-1 fees, as well as its disclosure of such fees, that are in violation of fiduciary duties imposed under the Investment Advisers Act. If the adviser self-reports the conflict and returns the money to investors, the Division of Enforcement will recommend that the Commission accept favorable settlement terms and not impose civil penalties that would otherwise have been imposed. Investment advisers that do not self-report and reimburse may face stronger sanctions. Bates Group recommends that advisers review their share class selection policies and procedures and disclosure practices. Follow the link for a more detailed review of the issues at stake and how Bates Group can help.
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Bates Research, Compliance and Regulatory Alerts | 02-07-18
The SEC has announced their examination priorities for 2018.
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Bates Research, Compliance and Regulatory Alerts | 01-08-18
FINRA has announced their regulatory and examination priorities letter for 2018.
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Compliance and Regulatory Alerts | 11-29-17
FINRA Issued Regulatory Notice 17-40 on November 21, 2017 to provide guidance to firms regarding Anti-Money Laundering program requirements under FINRA Rule 3310, following the adoption of FinCEN's Final Rule to Enhance Customer Due Diligence (CDD) Requirements for Financial Institutions.
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Compliance and Regulatory Alerts | 11-15-17
Covered financial institutions must assess and enhance their AML programs to be in compliance with the specific requirements of the new Rule by May 11, 2018. Is your firm ready?
Bates AML/BSA Consulting and Testifying Expert Susan Berger provides some background and details about the two new requirements which must be satisfied by the May 11 deadline.
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Bates Research, Compliance and Regulatory Alerts | 10-25-17
In two notices issued last week, the Financial Industry Regulatory Authority addressed a few longstanding issues. First, FINRA proposed expanding the legal options available to investors when filing a claim against an inactive firm or associated person. Second, FINRA requested comments on allowing compensated non-attorney representatives to continue to represent customers in disputes between investors and broker-dealers. Comments on both are due December 18, 2017. In addition, FINRA Executive Vice President of Regulatory Operations Susan Axelrod (at left) offers insight on how FINRA is identifying high risk brokers.
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Compliance and Regulatory Alerts | 08-31-17
On August 28, 2017, the Office of Management and Budget approved the Department of Labor’s (DOL) 18-month Fiduciary Duty Rule (Rule) delay request, extending the Transition Period and applicability of certain requirements and exemptions of the Rule until July 1, 2019.
DetailCompliance and Regulatory Alerts | 10-28-15
SEC's Division of Investment Management's recent initiatives to expand scrutiny of Registered Investment Advisers' Compliance and Risk Monitoring programs
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