From Morgan Lewis’ LawFlash, the SEC’s division of Investment Management’s announcement that it would allow its October 26, 2017 no-action letter to SIFMA to expire on July 23, 2023 “pulls the rug out from under ‘Hard Dollar’ research arrangements,” and raises questions about the possible investment adviser status of broker-dealers that, after that date, accept cash or “hard dollar” payments for research from investment managers subject to the EU Markets in Financial Instruments Directive II.

Read more here.

From our friends at Hardin Compliance Consulting LLC, helpful guidance for broker dealers and RIAs, as they plan their return:

• Question & Answer Employer Guide: Return to the Work in the time of COVID-19 by Faegre Drinker.
• Making your Office Safe to Return after COVID-19 by Riia O’Donnell of Workest.
• Preparing for Reentry in the US by Goodwin Procter LLP.
• Reopening Your Doors – BakerHostetler’s Return to Work Toolkit

Cari Hopfensperger from Hardin Compliance Consulting LLC shares these important deadlines and to-dos:

• Blue Sky Filings (Form D)
• Annual Renewal Program for IARD System
• 2020 Preliminary Renewal Statement is due in full on Monday, December 16, 2019.
• Supplemental Inventory Schedule (“SIS”)
• Statement Regarding Independent Public Accountant
• Rule 17a-5 Monthly and Fifth FOCUS Part II/IIA Filings
• Annual Audit Reports for Fiscal Year-End October 31, 2019  
• Supplemental Inventory Schedule (“SIS”)
• SIPC-3 Certification  
• SIPC-6 Assessment
• SIPC-7 Assessment