September Regulatory Updates from Jaqueline Hummel at Hardin Compliance Consulting LLC.

Topics include:

• IRS Ruling Allows Advisers to be Paid out of Fee-Based Annuities
• At Long Last… the SEC provides Guidance on Voting Client Proxies
• What’s New with Regulation Best Interest and Form CRS Relationship Summary?
• States Continue to Find Trouble Brewing in Crypto Markets
• Do You Need to Register as a Municipal Advisor?
• SEC Staff Issues No-Action Letter on Hiring Affiliated Sub-Advisers without Shareholder Approval
• New Dues for CPO/CTAs Engaged in Swap Activities
• Ignorance is not Bliss – NFA Takes Emergency Enforcement Action Against Walnut Creek, CA-Based CPO/CTA
• SEC Sanctions Levied Against Boston-Based Adviser for Breach of Fiduciary Duty to Senior Client
• Broker’s Clean Record of 32 Years Tarnished by SEC Insider Trading Fine
• The Other Shoe Drops… SEC Files Case Against Commonwealth Financial for Disclosure Failures for Revenue Sharing After Settling Charges in 12b-1 Sweep
• The Bigger the Conflict, the Bigger the Disclosure

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Regulatory Updates from Jaqueline Hummel at Hardin Compliance Consulting LLC.

Topics include:

• Reg S-P Compliance Violations Spelled out by SEC
• Heads Up! Massachusetts Amended the Data Breach Notification Law
• Ohio Requires Registered Reps and Investment Adviser Reps to Report Elder Abuse
• SEC Issues Digital Asset Analysis and No-Action Letter
• FINRA Issues Guidance for Communications with Customers Regarding Departing Representatives
• Attention Underwriting Syndicate Members who enter into Backstop Agreements
• FINRA Will Permit the Use of Electronic Signatures for Discretionary Accounts
• SEC Issues Guidance on Mutual Fund Reporting Requirements
• Liquidity Risk Management FAQs Updated
• NFA updated its Self Examination Questionnaire to assist firms in preparing for 2-9
• Ever Wonder What Happens if Your Firm Blows the Private Offering Exemption?
• Google Searches and Phone Calls Don’t Count as Extensive Due Diligence
• When Absolute Power Corrupts Absolutely
• FINRA Gives Broker-Dealer an “F” in Email Review

Read the full post here

Regulatory Updates from Jaqueline Hummel at Hardin Compliance Consulting LLC.

Topics include:

• Mr. Blue Skies:  A Primer on Form D and Blue Sky filings
• Speak Now or Forever Hold Your Peace — SEC Asks for Help on the Custody Rule
• Keeping up with  FINRA’s 529 Plan Share Class Initiative
• Registration Required If Your Firm Handles Orders in NMS Stocks, OTC Equity Securities, or Listed Options:  Rule 613
• Attention FINOPs – How To Report Operating Leases on FOCUS Filings
• Does Your Firm Publish Quotations in Unregistered Securities of Foreign Private Issuers?
• Modifications to Form N-PORT
• No Action Letter to the Independent Directors Council relaxes certain in-person voting requirements for fund boards
• MSRB Announces Effective Date for Amended Advertising Rules
• NFA to Require Swap Proficiency Testing
• Advisor Slammed for Charging Some Clients More for Same Services
• SEC Share Class Initiative Returning More Than $125 Million to Investors

• Stupid is as Stupid Does

  Read the full update here