On 7 May 2020, SEC published FAQs on Reg BI on externally-executed transactions. Recommendations to existing retail customers must comply with Reg BI at the time they were made, even if the customer executes the transaction with a different firm. Reg BI inapplicable if customer executes a self-directed account, no recommendation. Firms may deliver disclosures…
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SEC Best Interest v. Fiduciary
On Jul. 30, SEC's Hester Peirce spoke about best interest v. fiduciary. At 2018 NAPA DC Fly-In Forum, Peirce spoke of best interest v. fiduciary duty. Standards debated on intent of words and interpretation applied by BD and IA. Definitions Proposed regulation best interestrequires BDs to act in the best interest of the retail customer…
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