Financial Regulatory Forum

IA Brief: If your program is a “wrap”, be prepared

October 11, 2016
An investment adviser’s participation in a wrap fee program will not only increase its compliance and disclosure responsibilities but raise its regulatory profile with heightened focus on the programs. The focus was recently demonstrated with a Securities and Exchange Commission case in which two large firms settled complaints over wrap fee program compliance failures. Investment advisers are often creating or implementing new programs to meet their clients’ specific needs and ultimately improving their client experience. In recent years, the use of single fee programs or a more holistic approach to the advisory relationship has been embraced; however, programs that bundle particular services can often fall into the definition of a wrap fee program.


FINRA’s new suitability rule looms, with expanded customer-information requirements

June 27, 2012

By Nick Paraskeva

NEW YORK, June 27 (Thomson Reuters Accelus) – FINRA’s new suitability rule expanding customer information requirements and applying them to more transactions the is set to go into effect July 9, after delays requested by firms to get more time to adapt.

FINRA’s know-your-customer and suitability rules require brokerage changes, new strategies

June 25, 2012

By Morris Simkin, Thomson Reuters Accelus contributing author

NEW YORK, June 25 (Thomson Reuters Accelus) – Know-Your-Customer Rule (FINRA Rule 2090) and a new Suitability Rule (FINRA Rule 2111). When these rules are read together, the information required of a customer is materially expanded, even in the case of institutional investors.