FINRA Rule 2210: Effective Date for Complying with Amendments
Amendment to FINRA Rule 2210
SEC Provides Clarification of Custody Rule
On April 25, 2016, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management issued a no-action letter to the Investment Adviser Association (“IAA Letter”) giving relief to certain sub-advisers from surprise audits requirements under Rule 206(4)-2 under the Investment … Read More
The DOL Conflicts of Interest Rule and How it May Affect You (Part 1)
The final adopting release of the Department of Labor’s (“DOL”) Conflicts of Interest rule (the “Rule”),1 along with the separate releases of two new and four amended prohibited transaction exemptions (“PTE”) are now published in the Federal Register as of April … Read More
New DOL Conflicts of Interest Rule Has Arrived
On April 6, 2016, the Department of Labor’s (“DOL”) proposed rule expanding the definition of the term “fiduciary” and addressing certain conflicts of interest was adopted and published (the “DOL Conflicts Rule”). While the final rule is not as extensive … Read More
Robo-Advisors Come Under SEC Scrutiny
During a speech given yesterday at the SEC-Rock Center for Corporate Governance, Securities & Exchange Commission (“SEC”) Chairperson Mary Jo White discussed how the SEC’s National Exam Program are examining robo-advisors for adherence to requirements under the Investment Advisers Act … Read More
EB-5 Programs – When is FINRA Registration Required?
The EB-5 Program began in 1990 and is administered by the United States Customs and Immigration Service (“USCIS”). An EB-5 Program provides foreign nationals who have the means to invest in certain job creating commercial enterprises in the US, with … Read More