Earlier today, on February 21, 2020, the Massachusetts Securities Division (“MASD”) adopted amendments to its regulations in an effort to hold broker-dealers and agents to a fiduciary standard when dealing with their customers (the “Massachusetts Rule”). While I personally believe that the rule will ultimately be overturned based on federal preemption, in an effort toContinue reading “Massachusetts Fiduciary Rule and Regulation Best Interest”
Tag Archives: Regulation Best Interest
Logistical Wrinkles Relating to Form CRS
The rules and form implementing Form CRS became effective on September 10, 2019, and investment advisers and broker-dealers are currently in the early stages of preparing and developing internal procedures to comply with the rule and the form. By June 30, 2020, investment advisers registered with the U.S. Securities and Exchange Commission and broker-dealers willContinue reading “Logistical Wrinkles Relating to Form CRS”
The Disclosure Obligation under Regulation Best Interest
While this blog is typically focused on issues pertinent to investment advisers and their associated persons, Regulation Best Interest also extends to “associated persons of a broker dealer”. Many clients that I represent have relationships with broker-dealers and are responsible for supervising persons who are “associated persons of a broker dealer”. I often refer toContinue reading “The Disclosure Obligation under Regulation Best Interest”