OCIE issues Regulation S-P Risk Alert for Advisers and Broker-Dealers
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Practice Points for OCIE’s 2019 Exam Priorities and 2018 SEC Enforcement Actions Involving Advisers
In late 2018, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released its 2019 examination priorities, which cover not only investment advisers and registered funds, but also broker-dealers and transfer agents. To help you digest and better understand these 2019 exam priorities, our Washington, DC-based Investment Management practice has prepared a legal update giving an overview of the exam priorities specific to investments advisers, a brief description of certain key SEC 2018 enforcement actions…
SEC Enforcement Round-Up II: Electric Boogaloo
SEC Enforcement Round-Up
Changes Afoot for the Volcker Rule
A New Standard for Investment Adviser Fiduciary Duty?
The Department of Labor Fiduciary Rule: Lots of Work, Lots of Drama, Lots of Uncertainty
As most of you have heard, on March 15, 2018, the U.S. Court of Appeals for the Fifth Circuit issued an opinion vacating, in its entirety, the Department of Labor’s amendment to regulations defining “investment advice” for the purpose of determining who is a fiduciary (the “DOL Fiduciary Rule”) on the basis that the Department violated the Administrative Procedures Act and exceeded its regulatory authority. The Department had the right to request an en banc review…
