Treasury Department Proposes AML Regs for Advisers

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On August 25, 2015, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released proposed anti-money laundering (“AML”) regulations that would require investment advisers registered or required to register with the SEC to have written AML programs meeting certain minimum requirements … Continued

Three Steps in Developing an Effective IPS

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The initial questionnaire should accurately identify the client’s circumstances, investment objectives, risk tolerance, and all investment restrictions and preferences. Review of the questionnaire responses is a great time for the advisor to assess the client’s investment sophistication and to provide … Continued

Arbitration Clauses

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The state of Massachusetts, in a public letter, is calling on the U.S. Securities and Exchange Commission to prohibit Registered Investment Advisers from inserting mandatory arbitration clauses in their contracts, saying such clauses are widespread, not always in the best … Continued

BDs Closer to Fiduciary Rule

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The Securities and Exchange Commission plans to issue a “concept release,” which will also likely include a request for information, in the first quarter regarding its rule to put brokers under a fiduciary mandate.