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April 14 2017 - NRS Insights

SEC’s No-Action Letter Offers Critical Clarification on Custody Rule

On February 21, 2017, the SEC issued a highly anticipated no-action letter regarding Rule 206(4)-2 of the Investment Advisers Act of 1940—also known as the Custody Rule. In the letter, the SEC affirmed that a standing letter of instruction (SLOA) or similar asset transfer authorization arrangement would result in an investment adviser having custody of client assets.
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DOL
April 11 2017 - NRS Insights

DOL Rule Implementation Delayed, as Expected

As expected, the Department of Labor (DOL) has made official its proposal to delay implementation of its fiduciary rule by 60 days. The rule was originally slated to become effective on April 10. However, a President Trump directive to review the rule, with an eye to modify or repeal, led the DOL to propose a 60-day delay.
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Rule Change Alert
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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ADV
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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DOL
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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