August 8, 2020

Volume X, Number 221

August 07, 2020

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August 06, 2020

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August 05, 2020

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SEC Chairman Confirms June 30 Compliance Date for Regulation Best Interest and Form CRS

On June 15, 2020, SEC Chairman Jay Clayton released a public statement confirming the June 30, 2020 compliance date for Regulation Best Interest (Reg BI) and Form CRS. Reg BI establishes a new standard of conduct for broker-dealers when making a recommendation of any securities transaction or investment strategy (including account recommendations) to a retail customer. Form CRS is a disclosure document applicable to broker-dealers and registered investment advisers with retail investors, and is meant to reduce investor confusion about fees, conflicts of interest and the required standard of conduct for a particular firm. In his remarks, Mr. Clayton noted the SEC had engaged extensively over the past year with broker-dealers, investment advisers, market participants and regulatory partners such as FINRA, regarding the implementation of Reg BI and Form CRS. Based on the considerable progress observed, Mr. Clayton reiterated an earlier position from April 2020 that the June 30, 2020 compliance date for both rules was appropriate. Mr. Clayton further noted that the SEC’s work over the past several months had strengthened his view that the effects of the COVID-19 pandemic weighed substantially in favor of implementing Reg BI and Form CRS requirements as soon as practicable. 

Chairman Clayton’s public statement is available here.

© 2020 Vedder PriceNational Law Review, Volume X, Number 188

TRENDING LEGAL ANALYSIS


About this Author

Legal, Business, John Marten, Investment Attorney, Vedder Price Law FIrm
Shareholder

John S. Marten, a Shareholder in the Chicago office of Vedder Price, has substantial experience representing clients in the investment management industry.

As a member of the firm’s Investment Services group, Mr. Marten counsels clients on a wide variety of matters involving the application of the federal securities laws to investment companies, investment advisers and broker-dealers. He has significant experience counseling investment company clients with respect to new products and was recently involved in the creation of two mutual funds...

(312) 609 7753
Nathaniel Segal, Investment Attorney, Vedder Price Law Firm
Associate

Nathaniel Segal is an Associate at Vedder Price and a member of the Investment Services group. He focuses his practice on investment companies and investment advisers in connection with the organization and operation of investment products and services, including traditional mutual funds, closed-end investment companies (including interval funds and listed closed-end funds), variable insurance products and registered hedge funds, as well as mutual funds utilizing complex hedging and absolute return strategies. Mr. Segal has experience in conducting transactional due diligence and drafting regulatory disclosures in connection with fund reorganizations and management acquisitions. He counsels clients on a wide variety of regulatory matters, including interpretive and no-action letter requests and SEC exemptive orders, as well as governance matters and internal compliance procedures in response to SEC examinations and inquiries.

(312) 609 7747
Jacob Tiedt, Vedder Price, investment services attorney
Shareholder

Jacob C. Tiedt is a Shareholder at Vedder Price and a member of the Investment Services group.

Mr. Tiedt’s practice includes the representation of registered mutual funds, closed-end funds and exchange-traded funds; private funds; investment advisers; and other financial institutions on a broad range of regulatory, governance and compliance matters. Mr. Tiedt regularly counsels clients on matters relating to SEC registration, disclosure and compliance; shareholder solicitation; NYSE, Nasdaq and FINRA regulation; corporate governance; and board administration. Mr....

312-609-7697
David Soden Investment Attorney Vedder Price Chicago
Associate

David W. Soden is an Associate at Vedder Price and a member of the firm’s Investment Services and Litigation practice groups in the Chicago office.

His practice includes the representation of broker-dealers, investment advisers, family offices, private funds, registered mutual funds, closed-end funds, exchange-traded funds and other financial institutions on a broad range of legal, regulatory, governance, formation, and compliance matters.

Mr. Soden has significant experience in regulatory and compliance matters affecting broker-dealers, investment advisers, investment...

312-609-7793