CCOs of registered investment advisers need to understand the potential pitfalls around this investment strategy to ensure their firms’ compliance programs are ready for the next regulatory examination.
On June 30, the SEC’s new standard of conduct for broker-dealers (Reg BI) and Form CRS for advisers and brokers went live, with the Advisers Act fiduciary interpretation having already been in effect over the past year.
An adviser’s fiduciary duty might not look much different today than it did a year ago, viewed strictly from the standpoint of the obligations owed. After all, advisers must still meet fundamental duties of loyalty and care.
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