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Observations Regarding Fixed-Income Principal and Cross Trades

Observations Regarding Fixed-Income Principal and Cross Trades by Investment Advisers from an Examination Initiative

On July 21, 2021, the SEC’s Division of Examinations (the Division) issued a Risk Alert detailing more than 20 examinations of investment advisers who engaged in cross trades, principal trades, or both, involving fixed-income securities as part of the Division’s FIX Initiative.

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Best Practices in Share Class Reviews

Best Practices in Share Class Reviews

The following is a list of best practices applicable to the share class review process. This guide aims to provide helpful tips regarding the process of replacing an advisory client’s existing mutual fund share class with a lower-cost alternative, where it is

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Preparing for the Full Implementation of the DOL Fiduciary Rule

Preparing for the Full Implementation of the DOL Fiduciary Rule

The second iteration of the Department of Labor Fiduciary Rule – PTE 2020-02 (DOL Fiduciary Rule) became effective on Feb. 16, 2021. However, the Department of Labor (DOL) provided that it would not pursue enforcement actions against firms who work “diligently” to

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New York Investment Adviser Representative Registration

New York Investment Adviser Representative Registration

Historically, New York State has not required the registration of investment adviser representatives (IARs). New York has adopted regulations providing registration and examination requirements for IARS. This article focuses upon the examination and registration requirements applicable to IARs of federally covered investment

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