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At the secs April 18, 2018 meeting, Chairman Clayton explained that the goal of Form crs is to provide clear rules for how registered investment advisers present themselves to their clients, thus making it easier for. 401(k) to understand the services and standard of care they are being offered. Form crs attempts to meet this goal in two primary ways. . First, it creates a new customer relationship summary form that both broker-dealers and registered investment advisers would be required to provide prior to providing services and would be designed to present a short and easily understood overview of key information. . Second, it would impose new labeling rules on registered investment advisers and broker-dealers.  Most significantly, it would prohibit broker-dealer firms and affiliated persons from using the words adviser or advisor in their names or titles. The customer relationship summary appears to have been based somewhat on the bic exemptions disclosure requirements. . In this regard, like the bic exemptions requirement, the customer relationship summary would need to be provided to all natural persons (regardless of net worth as well as trusts or similar entities that represent natural persons.

In addition to providing color on these existing wallpaper duties, the sec requests comments on additional requirements for advisers. . Specifically, the sec seeks resume input on several questions, including whether (1) there should be federal licensing and continuing education requirements for investment adviser representatives, (2) investment advisers that do not have custody should be required to provide periodic account statements that disclose fees, and (3). Notably, while the fiduciary duty owed by investment advisers is described in the release as the highest standard of conduct, the standard departs from the wording used to describe fiduciary status under erisa section 404(a) in a handful of significant ways. Under erisa, the standards of care are described as the standards of prudence and loyalty. . The prudence standard is analogous to the duty of care requirement in the commissions interpretation of the Advisers Act. . Under erisa, the standard requires a fiduciary to act, with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters would use in the conduct of an enterprise. Essentially, it imposes a broad requirement to act like a thoughtful expert would in pursuing the aims of the client. . What is surprising here is that while the secs Regulation Best Interest reads like a less prescriptive best Interest Contract Exemption, the secs commentary on the standard of care owed by investment advisers is more detailed than erisas description of the standard of care owed. As investment advisers to iras or retirement plans would likely be considered fiduciaries for purposes of erisa under the 1975 five part Test, it will be important to harmonize the sec and dol care standards. Form crs the final piece in the secs package is a proposed requirement that broker-dealers and investment advisers provide a customer or client relationship summary to be known as Form crs, prior to providing client services. .

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The duty to seek best execution requires an adviser to seek to obtain the hippie execution of transactions for each of its clients such that the clients total cost or proceeds in each transaction are the most favorable under the circumstances. . Again, the sec notes that an adviser can consider factors such as the value of research, execution capability, commission rate, financial responsibility, and responsiveness, in addition to total commission. Notably, the sec suggests that an adviser can limit but not completely eliminate the duty to provide advice and monitoring by contract. Further, the sec describes that this duty extends to all personalized advice it provides the client, including an evaluation of whether the clients account or program type continues to be in the clients best interest. The sec also describes the duty of loyalty as requiring that an investment adviser not favor its own interest over those of a client or unfairly favor one client over another. . to satisfy this duty, an investment adviser must make a full disclosure of all material facts relating to the advisory relationship. . Significantly, the sec notes that a conflict of interest may be cured by informed client consent after a full and fair disclosure. . That said, with respect to disclosing conflicts, the sec cautions that merely stating that a conflict may exist is insufficient if a conflict does in fact exist, and that if a conflict is too complex to adequately explain, an investment adviser is expected to eliminate.

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It does this by describing the component parts of the common law fiduciary duties of care and loyalty, which it interprets as requiring that an investment adviser at all times, serve the best interest of its clients and not subordinate its clients interest to its. Significantly, the sec provides a mechanical description of what is required by the existing duties under the Advisers Act. . First, the sec describes the duty of care as being comprised of three prongs, namely the duties to (1) act and provide advice in the best interest of a client, (2) seek best execution, and (3) provide advice and monitoring. The duty to provide advice in the best interest of a client itself has two parts. . Specifically, it requires an investment adviser to (a) make a reasonable inquiry into a clients financial situation, level of financial sophistication, investment experience, and investment objectives and (b) provide personalized advice that is suitable for and in the best interest of the client based. In determining that advice is in the best interest of an investor, the sec notes that cost is just one of many factors an investment adviser should consider. . Other factors include investment objectives, characteristics, liquidity, risks and potential benefits, volatility and likely performance in a variety of market and economic conditions. . The sec cautions, however, that an adviser could not reasonably believe that a recommended security is in the best interest of a client if it is higher cost than a security that is otherwise identical, including any special or unusual features, liquidity, risks and potential.

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At the outset, the sec notes that broker-dealers should have the flexibility to make disclosures by various means. . The plan sec advises that disclosures that are required to be made prior to the time a recommendation could be made, including: At the beginning of a relationship (e.g., in the account opening agreement On a regular or periodic basis when previously disclosed information becomes materially. The material facts relating to the scope of the relationship and which must be disclosed would include: That the broker-dealer is acting in a broker-dealer capacity with respect to the recommendation; The fees and charges that apply to the retail customers transactions, holdings, and accounts;. Additionally, the disclosure Obligation requires that the broker-dealer explicitly disclose all material conflicts of interest associated with the recommendation. . The sec defined a material conflict of interest as a conflict of interest that a reasonable person would expect might incline a broker-dealer consciously or unconsciously to make a recommendation that is not disinterested. .

It is unclear whether this is a higher or lower standard than the bic exemptions definition, which provided that a material conflict of interest is a financial incentive that a reasonable person would conclude could affect the exercise of its best judgment as a fiduciary. Regulation Best Interests disclosure requirements follow the same layered format as the bic exemption. . The sec appears to share the dols view that a layered approach to disclosure is most appropriate. . In this regard, the form crs disclosures would constitute the thrust of the initial layer of disclosure, while the disclosure Obligation would require additional, more specific and detailed levels of disclosure. Interestingly, the sec highlighted that firms are only required to reasonably disclose material conflicts of interest. . In the secs view, this means that compliance with the disclosure Obligation will be measured against a negligence standard as opposed to the strict liability standard generally associated with the bic exemption. Investment Adviser Standard In addition to the specific standard of care for broker-dealers described above, the best Interest Package contains a proposed sec interpretation of the common law fiduciary standard owed by investment advisers under the Advisers Act. .

This prong requires that broker-dealers (1) establish, maintain, and enforce written policies and procedures reasonably designed to identify, and at a minimum disclose, or eliminate, all material conflicts of interest that are associated with recommendations covered by regulation Best Interest, and (2) establish, maintain, and. The sec construed the term financial incentive broadly and in line with how the dol has historically interpreted the definition of compensation for purposes of defining when a person is providing investment advice for a fee or other compensation under erisa section 3(21 a ii). . The sec describes material conflicts of interest that arise from financial incentives to include: Compensation practices established by the broker-dealer including fees and charges for products sold, employee compensation or employment incentives "s, bonuses, sales contests, special awards differential or variable compensation, and incentives tied. Sales of propriety products or services or products of affiliates and principal transactions. In the case of material conflicts of interests associated with financial incentives, the proposal would require broker-dealers to either eliminate the conflict entirely, or mitigate the conflict in addition to providing disclosure. . The sec described that material conflicts of interests could be mitigated through various means which could include the creation of policies developed with an aim to: avoid compensation thresholds that disproportionately increase compensation through incremental increases in sales; Eliminate compensation incentives between product lines.

Notwithstanding the foregoing, the sec did describe that certain material conflicts of interest arising from financial incentives may be difficult to mitigate and may be more appropriately avoided in their entirety. . Those practices include the payment or receipt of certain non-cash compensation taking the form of sales contests, trips, prizes and other similar bonuses based on sales of certain securities or accumulation of assets under management. . This appears to be consistent with the dols prohibition against the use of"s, appraisals, bonuses, and sales contests within the warranty sections of the bic exemption. Under the regulation Best Interest, broker-dealers would be permitted to exercise their judgment to determine whether a conflict can be effectively disclosed or require some other conflict mitigation strategy. . Importantly, the sec stated that it would be reasonable for a broker-dealer to use a risk-based compliance and supervisory system that would allow the broker-dealer to focus on specific areas of their business that pose the greatest risk of non-compliance. . Thus, unlike the bic exemptions warranty requirements, which strictly prohibited certain conflicts of interest, the sec rules require only that the broker-dealer enforce written policies and procedures to mitigate or eliminate such conflicts. Disclosure Obligation Regulation Best Interest also requires that broker-dealers satisfy the disclosure Obligation. . Importantly, a broker-dealers Disclosure Obligation is in addition to and distinct from the form crs obligation (discussed below) which must be satisfied by both broker-dealers and registered investment advisers. The disclosure Obligation requires that, prior to or at the time of a recommendation, the broker-dealer—or a or natural person who is an associated person of a broker or dealer—reasonably disclose to the retail customer, in writing, the material facts relating to the scope and.

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The sec also indicated it is of the view that the other requirements of the Impartial Conduct Standards were not needed to be included Regulation Best Interest (e.g., restrictions on misleading statements and receiving more than reasonable compensation as these obligations are already covered. Importantly, the sec did not change the definition of a recommendation for purposes of Regulation Best Interest, and instead preserved the meaning that has been interpreted under existing broker-dealer regulation under the federal securities laws and self-regulatory organization rules in dream order to provide clarity. The sec also notes that in determining whether a broker-dealer has made a recommendation, factors that have historically been considered in the context of broker-dealer suitability obligations should be considered, namely whether the communication could reasonably be viewed as a call to action or reasonably. Consistent with existing sec authority, one-time recommendations are included as recommendations under Regulation Best Interest. . The sec also specifically notes that rollover recommendations from a plan to an plan ira would be covered by regulation Best Interest. On the other hand, and in a substantial deviation from the dols interpretation of a recommendation under the fiduciary rule, regulation Best Interest does not cover a broker-dealers recommendation of a brokerage account versus an advisory account. Conflict of Interest Obligation, the second prong of Regulation Best Interest is the conflict of Interest Obligation. .

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Have a reasonable basis to believe that a series of recommended transactions, even if in the retail customers best interest when viewed in isolation, is not excessive and is in the retail customers best interest when taken together in light of the retail customers investment. Notably, the sec advises that its Care Obligation incorporates the underlying policy objectives of the bic exemptions Impartial Conduct Standards. . The care Obligation includes a process element for broker-dealer recommendations that resembles the prudent process requirement for fiduciaries rooted in erisa section 404 and incorporated by the bic exemptions Impartial Conduct Standards. However, the secs standard english also appears to be more forgiving to some extent as Regulation Best Interest requires only that the broker-dealer have a reasonable basis to believe that the broker-dealer and their associated persons recommendations satisfy the three prongs of the care Obligation. The sec emphasizes that Regulation Best Interest is not intended to limit access to particular products and services or to affect the availability of transaction-based accounts. . Moreover, the sec notes that while cost is an important factor with any recommendation, it is not a determinative factor. . Instead, the sec contemplates that a broker-dealer may have a reasonable basis to conclude that a higher cost security or strategy is more appropriate for an investor based on other characteristics and in light of the retail customers investment profile. At the same time a broker-dealer would be unable to satisfy the care Obligation, even with proper disclosure, if it recommends a costlier alternative to the retail investor where the securities were otherwise identical. The sec expressed the view that Regulation Best Interest would result in efficiencies for broker-dealers who have already constructed policies and procedures to comply with the dols Impartial Conduct Standards.

regulated under the securities Exchange Act of 1934 (Exchange Act) with other advisory relationships and regulatory regimes, including the dols Fiduciary rule and Best Interest Contract Exemption (bic exemption while preserving investor. Throughout its regulatory package, the sec emphasizes that its best interest standard goes beyond suitability and cannot be satisfied through disclosure alone. . The sec also acknowledges that Regulation Best Interest, in combination with existing broker-dealer obligations, is generally more prescriptive than the standard of care required for advisers under the Investment Advisers Act of 1940 (Advisers Act). Regulation Best Interest would require that broker-dealers and their associated persons act in the best interest of the retail customer at the time the recommendation is made without placing the financial or other interest of the broker-dealer or natural person who is an associated person. Unlike the dols Fiduciary rule and bic exemption—both of which have been vacated by the fifth Circuit—the secs best interest standard of care does not require that the recommendation be made without regard to the financial or other interests of the broker-dealer. The omission of this language, which was also included in section 913(g) of the doddFrank wall Street Reform and Consumer Protection Act (Dodd-Frank Act) is significant, and reflects the secs concerns that this language could be inappropriately construed to require a broker-dealer to eliminate all. In this regard, the sec notes that conflicts of interest are inherent in any principal-agent relationship, and that it does not intend for our standard to prohibit a broker-dealer from having conflicts when making a recommendation. A broker-dealer is deemed to comply with Regulation Best Interest if it satisfies the regulations three core obligations: (i) the care Obligation, (ii) the conflict of Interest Obligation, and (iii) the disclosure Obligation, care Obligation, the care Obligation requires that broker-dealers exercise reasonable diligence, care.

having said that, the secs effort to protect retail investors and retirement savers has been carefully re-calibrated in an effort to arrive at more workable standard of care and with less extensive disclosure obligations. . Whether the regulated community will embrace the best Interest Package as an appropriate compromise remains to be seen. Below, we provide an overview of the core provisions of the best Interest Package, as well as high-level observations on how it tracks or departs from the dols Fiduciary rule. . Once the best Interest Package is published in the federal Register, the public will have 90 days to submit comments to the sec. While it would be easy to view the best Interest Package as simply an extension of the dols previous efforts, the proposal is highly significant for the retirement industry and merits close attention. . If the sec effort gains traction, it could form the basis for future dol efforts to regulate the delivery of investment advice under write the Employee retirement and Security Act of 1974 (erisa) and the Internal revenue code (the code). In the near-term, retirement service providers will need to carefully consider whether compliance with the best Interest Package when recommending securities to ira clients will trigger obligations under erisa and the code. . For example, when a broker-dealer meets its obligations under the best Interest Package when recommending securities to an ira client, it might also meet the dols five part test for determining when a securities recommendation is fiduciary investment advice for purposes of erisa and the. If that is the case, those broker-dealer entities and their registered representatives will need an exemptive relief strategy to avoid giving rise to prohibited transactions under the code.

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After the fifth Circuits March 15, 2018 decision striking down the department of Labors (the dol) Fiduciary rule, many in the retirement space expected to finally be able to take a well-deserved break from years of regulatory drama and related compliance anxieties. . Instead, barely a month later, on April 18, 2018, the securities and Exchange commission (the sec) signaled the opening of a new round in the effort to regulate the delivery of advice by voting to release a package of three rules, namely: (i). Regulation Best Interest (Regulation Best Interest (ii proposed Commission Interpretation Regarding Standard of Conduct for Investment Advisers; Request for Comment on Enhancing Investment Adviser Regulation (Investment Adviser Standard and (iii form crs relationship Summary; Amendments to form adv; Required Disclosures in Retail Communications and Restrictions. sec chairman jay clayton described the goal of the best Interest Package as being to fill any gap between reasonable investor expectations and legal standards. . Public Statement: overview writing of the Standards of Conduct for Investment Professionals Rulemaking Package (April 18, 2018). The best Interest Package proposes a mix of heightened standards of care on the part of registered broker-dealers and investment advisers and new sets of disclosure obligations for both. . Those who have followed the dols recent efforts to regulate the delivery of investment advice will recognize many of the principles contained within the best Interest Package, since they reflect to a large extent those of the dol fiduciary rule. .

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