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NASAA issued two statements regarding the SEC's Investor Advisory Committee's ("IAC") recommendations on SEC investment adviser exam funding and on the fiduciary duty for broker-dealers. In short, NASAA favored increased funding to allow the SEC to conduct more examinations of investment advisers. NASAA also supported imposing a fiduciary obligation on broker-dealers that provide personalized advice. Lofchie Comment: Both of NASAA's statements raise important policy considerations, and ought to illustrate the difficulty of obtaining a benefit that is cost-free. As to NASAA's recommendation

The MSRB issued a restated interpretive notice to MSRB Rule G-29 ("Availability of Board Rules") which states that the MSRB will no longer be printing and distributing its rulebook on an annual basis, but instead will be maintaining its rulebook online. The new Rule G-29 interpretive notice states that dealers may still make the MSRB's rules available to customers by a number of other means, including providing access to the MSRB's website, and using printed versions or software products produced by other companies. To ensure that the digital availability of MSRB rules meets the needs of

SIFMA and the International Swaps and Derivatives Association, Inc. ("ISDA") submitted comments to the CFTC regarding the available-to-trade submissions by Javelin SEF, LLC and trueEx, LLC for certain interest rate swaps, pursuant to CEA Section 5(c) ("Common Provisions Applicable to Registered Entities") and CFTC Rule 40.6 ("Self-Certification of Rules"). According to the letter regarding Javelin, SIFMA and ISDA do not believe the Javelin submission is ready for action in its current form because it "lacks the specificity needed" to determine whether it meets the six factors set out in CFTC

The SEC Staff of the Office of Credit Ratings published a report regarding credit rating agency independence. The report was submitted to the Committee on Banking, Housing, and Urban Affairs of the U.S. Senate, and the Committee on Financial Services of the U.S. House of Representatives, and is being submitted pursuant to Dodd-Frank Section 939C ("Securities and Exchange Commission Study on Strengthening Credit Rating Agency Independence"). Part One of the report describes the independence of nationally recognized statistical rating organizations ("NRSROs"), and how such independence affects