NRS Insights Blog
April 7 2017 - NRS Insights
Rule Change Alert! New Consolidated Rule for Personal Trading Accounts
April 3, 2017, is the effective date of FINRA’s new consolidated Rule 3210, Accounts at Other Broker/Dealers and Financial Institutions. This rule consolidation replaces NASD Rule 3050 and incorporates NYSE Rules 407 and 407A as well as NYSE Rule Interpretations 407/01 and 407/02.
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April 5 2017 - NRS Insights
DOL Delays the Fiduciary Rule to June 9, 2017
The Department of Labor has issued a final rule that delays the applicability date of the Fiduciary Rule from April 10, 2017 to June 9, 2017. The compliance date of January 1, 2018 has not been delayed.
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March 23 2017 - NRS Insights
Adviser’s Act Amended to Require More Form ADV Information
The SEC recently amended the Investment Adviser’s Act of 1940 to add several new requirements to Form ADV reporting for Investment Advisers.
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March 23 2017 - NRS Insights
Adviser’s Act Now Requiring Performance Reporting Documentation
IAs will be required to maintain additional materials related to the calculation and distribution of performance information beginning October 2017. Currently, advisers are only required to maintain records supporting performance claims that were distributed to 10 or more people. The amendments will now require this type of documentation to be kept for all information supporting performance claims, even if given only to one investor or prospect.
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March 23 2017 - NRS Insights
“Fiduciary Rule” Will Not Be Enforced Until Effective Date Is Cleared Up
In its latest release concerning the fiduciary rule, the Department of Labor has issued a “field assistance bulletin” to clarify the fast-approaching April 10 effective date, and what would happen if a final decision on the delay has not been reached before the official implementation date. This is a welcome announcement to financial services firms that have been in limbo since President Trump’s directive to review and potentially revise or rescind the rule, in addition to the DOL’s subsequent proposal to delay the rule’s applicability date by 60 days.
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March 13 2017 - NRS Insights
Robo-Technology presents unique Compliance Challenges
For any skeptics, late adopters or those who viewed robo-technology as a passing fad, the time for ambivalence is over; the verdict on robo-advisers is in and they are here to stay. Robos are well positioned to thrive as technology continues to advance, as small investors increasingly find traditional advisory services cost-prohibitive, and as regulatory and industry forces such as the DOL Fiduciary Rule and the trend toward passive management styles combine to create the perfect climate for robo-tech success.
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March 13 2017 - NRS Insights
First Steps Taken in Delay of the DOL’s Fiduciary Rule
On Wednesday, March 1, the Department of Labor released a proposed rule that would extend the effective date of the new ERISA Fiduciary Rule by 60 days, delaying implementation of the final rule from the current April 10 compliance date to June 9, 2017.
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March 9 2017 - NRS Insights
How Multi-Branch Advisers Can Comply with New OCIE Initiative
Why was the alert issued? OCIE staff “observed an apparent increase in the use of investment advisers employing a business model with numerous branch offices and operations geographically dispersed from the adviser’s principal or main office.”
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February 17 2017 - NRS Insights
DOL Files for Delay of Fiduciary Rule
On February 9 the DOL filed a request with the Office of Management and Budget (OMB) for a delay in the April 10 Applicability Date for the Fiduciary Rule. The text of the request is expected to appear in the Federal Register shortly after the OMB review is completed. Published sources are indicating that the proposal is for a 180-day delay, which would be consistent with the preliminary drafts of President Trump’s Memorandum of February 3.
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February 9 2017 - NRS Insights
DOL Fiduciary Rule Upheld in Texas Federal Court
On February 8, 2017 Chief Judge Barbara M.G. Lynn of the Northern District of Texas upheld the DOL fiduciary rule against lawsuits by SIFMA, the US Chamber of Commerce, the Financial Services Roundtable and others. The judge issued an 81 page opinion addressing, and refuting, each of the plaintiffs’ arguments. The judge also denied a motion to stay the proceedings that had been filed by the US Department of Justice filed just that day.
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