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Your professionally curated research and reference resource fully integrating treatise and how-to guidance with underlying laws, rules, interpretations, and hundreds of sample documents.

New Marketing Rule Effective

The new marketing rule became effective on May 4. However, there is an 18 month transition period. So the drop dead compliance date is Nov. 4, 2022 Please refer to our collection of materials on the new rule in the adjoining News column for more information.

Adviser Regulatory & Compliance News

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SEC:  CRS Disclosures Must Be Timely

July 28, 2021

On July 26, 2021, the SEC announced the resolution of 26 administrative actions regarding failure to timely deliver Form CRS to advisory or brokerage clients. From the press release, "According to the SEC’s orders, each of the firms charged today missed those regulatory deadlines. The orders find that none of the firms filed or delivered its Form CRS, or posted it to its website, until being twice reminded of the missed deadlines by their regulators—in the case of investment advisers, by the SEC’s Division of Examinations, and in the case of broker-dealers, by the Financial Industry Regulatory Authority." Please click the headline to this summary to access the Press Release and the links to the 26 settled actions.

SEC Issues Risk Alert Re:  Wrap Fee Programs

July 23, 2021

July 21, 2021 was a busy day at the Examinations Division: they issued two Risk Alerts. One related to trading practices and is discussed in a separate blog entry. The second relates to advisers' wrap fee programs. EXAM staff noted their prioritization of examining advisers that have wrap fee programs or otherwise participate in such programs. A more complete summary can be accessed by clicking the headline to this summary.

Marketing Rule Reference Materials

July 7, 2021

While we draft a whole section of the website regarding the recently adopted Marketing Rule, this posting provides members with a good collection of materials for reference. Note that for many advisers there will be a critical choice over the next year to 18 months: stay with the old rules until the new rule compels compliance (Nov. 4, 2022) or opt in to the new rule's requirements beginning May 4, 2021. But it's a one way path: once you've opted in, you must comply with the new rule. Please click the headline to this summary to access the reference page.

Upcoming Events

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