Update on SEC Standards of Conduct Package/Weekend Reading

The Securities and Exchange Commission’s package of rule amendments and interpretations on broker-dealers’ and investment advisers’ standards of conduct will be published today in the Federal Register. The SEC releases were issued on June 5. Publication does not affect the timing of the rule and form amendments, which have a compliance date of June 30, 2020. However, the interpretive releases are effective upon publication. Here are the links:

The U.S. House of Representatives has added a provision to the appropriations bill for the fiscal year beginning October 1, 2019, and ending September 30, 2020, to provide that none of the appropriated funds for that fiscal year may be used by the SEC to implement, administer, enforce, or publicize any part of the package. The provision is not expected to be included in the Senate version of the appropriations bill.

Larry Stadulis, Sara Crovitz and John Baker will participate in a 90-minute Strafford webinar on July 31, from 1:00 to 2:30 pm, on Regulation Best Interest and Other New SEC Standards of Conduct: Impact on Broker-Dealers, Investment Advisers and Investment Companies. The webinar will provide continuing legal education credit, and there is an early registration discount for people who sign up by today. You can register here.

We have already presented a shorter (one-hour) webcast, which aired July 9, featuring Larry Stadulis, Alan Goldberg, and John Baker, on the same subject. This webinar is less detailed than the Strafford webinar will be and does not provide continuing legal education credit, but it does have the advantage of being free. You can view the webcast here.

In addition, we have published a number of client alerts from different perspectives on the SEC rulemaking. You can find all of our analysis in a single downloadable PDF here.

Have a nice weekend.

Blog Authors

Sara P. Crovitz

Sara Crovitz, most recently Deputy Chief Counsel and Associate Director of the U.S. Securities and Exchange Commission’s Division of Investment Management, provides counsel on all aspects of investment company and investment adviser regulation. She worked at the SEC for 21 years, including 17 years in the Division of Investment Management focusing on issues under the Investment Company and Investment Advisers Acts of 1940. While in the Division, Sara supervised the provision of significant legal guidance to the investment management industry through no-action and interpretive letters, exemptive applications, IM guidance updates and other written and oral means.

William T. Mandia

William Mandia represents financial institutions and insurers in complex commercial and class action litigation. He regularly defends and advises life insurers, intermediaries, banks, broker-dealers, investment advisers, and other financial services providers in connection with sales practices claims arising from a wide range of financial and life insurance products, including, but not limited to, claims for alleged breach of fiduciary duty, fraud, and violations of state consumer protection laws.

Peter M. Hong

Peter Hong uses his many years of service at the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) to guide clients through the various regulatory requirements involved in the offer of financial services and products. His practice includes the registration and regulation of investment advisers, broker-dealers, commodity trading advisers, commodity pool operators, and introducing brokers under federal and state laws, as well as the formation and ongoing compliance obligations of registered and private investment companies.