Carl Ayers
This document proposes to extend for 60 days the applicability date defining who is a “fiduciary” under the Employee Retirement Income Security Act (ERISA) and ...
The proposed amendments would amend the list of events for which notice is to be provided to include (i) incurrence of a financial obligation of ...
This letter went to an investment advisory firm in 2016.
Ask questions in the beginning of a relationship. In the case of a husband and wife: Do you have a power-of-attorney for each other? Do ...
A source passes along the firm's recent document request letter from an advisory firm SEC exam.
If the new guidance from the SEC’s Division of Investment Management on what constitutes custody deprives the industry of an outright victory, it at least ...
the Staff believes that, depending on their business models and operations, robo-advisers should keep in mind certain unique considerations as they seek to meet their ...
Given the “unique challenges and opportunities” for robo-advisers, the SEC’s Division of Investment Management issued guidance suggesting compliance steps for this “fast-growing trend within the ...
If author Stephen King had it right when he said “brevity makes sweetness,” then the CFTC’s rules around bona fide hedging can seem as sour ...