Division of Investment Management Releases FAQs on Financial Conflicts for RIAs

On Friday, October 18, 2019, the U.S. Securities and Exchange Commission’s Division of Investment Management released “Frequently Asked Questions Regarding Disclosure of Certain Financial Conflicts Related to Investment Adviser Compensation.” The FAQs discuss certain compensation arrangements and related disclosure obligations arising from both the investment adviser’s fiduciary duty and Form ADV. Nothing in the FAQs should come as a surprise to investment management attorneys. However, now is a good time for investment advisers to analyze all of their financial incentives and conflicts of interest and ensure that they are appropriated mitigated and disclosed.


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