September 22, 2021

Volume XI, Number 265

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SEC Issues No-Action Letter Regarding Institutional Family Offices

On December 23, 2020, the Securities and Exchange Commission issued a no-action letter regarding family offices and Regulation Best Interest.

Specifically, the SEC staff indicated that the SEC would not treat Institutional Family Offices as “retail customers” for broker dealers for purposes of Regulation Best Interest and broker dealers’ Form CRS. An Institutional Family Office is defined as “a family office that has one or more experienced securities or financial services professionals, manages total assets of $50 million or more, does not rely on the broker-dealer for recommendations, and has professionals who are independent representatives of their family clients.”

See the SEC no-action letter.

©2021 Katten Muchin Rosenman LLPNational Law Review, Volume XI, Number 15
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About this Author

Susan Light, Katten Law Firm, Finance Law Attorney, New York
Partner

Susan Light focuses her practice on financial services regulatory matters. She counsels broker-dealers, hedge funds, investment banks and financial services clients on enforcement issues involving the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), other self-regulatory organizations (SROs) and state and federal regulatory authorities. She has particular experience related to sales practice issues, financial and operational issues, anti-money laundering, crowdfunding, cybersecurity, and cryptocurrencies.

...
212-940-8599
Associate

Timothy Kertland concentrates his practice on transactional, corporate and regulatory aspects of financial services matters. Timothy is able to provide legal services to a wide variety of clients including proprietary trading firms, hedge funds, broker-dealers, registered investment advisers, and commodity trading advisers.

While in law school, Timothy served as an editor of the Virginia Tax Review. As a first-year law student, he represented the University of Virginia School of Law at the National...

312-902-5343
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