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Urgent: What the SEC releases require you to do ahead of RegBI
On June 5 the SEC issued adopting releases for Reg BI and Form CRS, and also issued two interpretive releases outlined below:
- The meaning of “fiduciary” as applied to the Advisers Act;
- The meaning of “solely incidental” when distinguishing brokerage and advisory services
While most attention has been directed to Reg BI and Form CRS, these new requirements share a compliance date of June 30, 2020, giving BDs and IAs more than a year to prepare.
By contrast, these two interpretive releases become effective upon publication in the Federal Register, making the impact on your compliance program immediate and demanding that you act now.
And this will require changes for many (or most) BDs and IAs – and will have far reaching consequences for most dual registrants.
Depending on your firm’s business practices, the new releases will have an immediate impact on the following:
- Reviewing and revising disclosures
- Obtaining client’s “informed consent” to disclosures
- Adopting or modifying written policies and procedures
- Documenting the obligation to monitor client accounts
- Determining how much account monitoring is permissable
- Identifying acceptable forms of “limited discretion”
- Adopting or modifying written supervisory procedures
- Reviewing and revising advertisements in light of the latest guidance
This Complimentary webinar will cut through the legalese and unpack the content of these releases so that you can readily identify the changes you need to make now as the first step in getting your compliance program ready for Reg BI and Form CRS. NRS Consultants with industry and regulatory backgrounds will give you the practical knowledge you need to bring your compliance program in line with the current releases.
In addition, we will preview our in-depth sessions focusing on Reg BI and Form CRS at our upcoming Fall Conference and outline how the NRS Consulting team can help you.
There’s no time to lose!