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:
- Regulation Best Interest
- Form CRS
- Investment Advisers Interpretive Release
- Interpretive Release on the Broker-Dealer Exclusion From the Definition of “Investment Adviser”
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.
George Michael Gerstein advises financial institutions on the fiduciary and prohibited transaction provisions of ERISA. As co-chair of the fiduciary governance group, he assists clients with tracking, and understanding, the numerous fiduciary developments at the federal and state levels, including the rules and regulations of governmental plans. He also advises clients with respect to the fiduciary duty implications of ESG investing.