February 13, 2020—This afternoon, the National Association of Insurance Commissioners (NAIC) voted to recommend that the states amend their annuity sales regulations to require insurance agents to “act in the best interest of the consumer when making a recommendation of an annuity.” The action came in the form of an amendment to the NAIC’s 2010 Suitability in Annuity Transactions Model Regulation, which was adopted by 45 states and the District of Colombia in the wake of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act. The new best-interest standard requires insurance agents to exercise a greater degree of care […]
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Form CRS: An Overview of the SEC-Mandated Customer Relationship Summary Due June 30, 2020
About Form CRS In June 2019, the SEC adopted requirements (SEC Release 34-86032) for registered investment advisers, broker-dealers, and dual-registrants that do business with retail investors to file Form CRS (customer relationship summary). Form CRS is intended to inform retail investors about: The types of client/customer relationships and services the firm offers; Fees, costs, conflicts of interest, and required standard of conduct associated with those relationships and services; Whether the firm and its financial professionals currently have reportable legal or disciplinary history; How to obtain additional information about the firm. Form CRS applies to registered investment advisers, broker-dealers, and dual […]
Continue readingMore TagKey Takeaways: FINRA’s 2019 Report on Examination Findings and Observations
On October 16, 2019, FINRA published its 2019 Report on FINRA Examination Findings and Observations. This report is a useful resource for firms to leverage to improve their compliance and risk management programs. One of the findings in the report pertains to failure to effectively monitor for and react to regulatory changes. Firms are required to review regulatory changes against their supervisory systems, including their written supervisory procedures and training programs. FINRA found that some firms did not adequately respond to recent regulatory changes such as FinCen’s new Customer Due Diligence (CDD) obligations and requirements around Financial Exploitation of Specified […]
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