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Michael Koch

Date for Reg BI Remains Unchanged Ramifications related to COVID-19 have spread far and wide. They range from only “essential business” remaining open to how we buy groceries and other goods to an extension for filing... [...] Read more
Zen Master’s Crypto: Celebrity Endorsements Require Disclosures Joining a list of other celebrities to jump into the financial investment or fintech space, action movie star Steven Seagal is one that also faced charges for nondisclosure of compensation.... [...] Read more
Making the Cut: Factors for Registrant Examination Numerous factors are taken into consideration when the SEC’s Office of Compliance Inspections and Examinations (OCIE) compiles its annual list of registrants to audit. In a recent conference call conducted... [...] Read more
OCIE Observations on Cybersecurity and Resiliency Practices On January 27, 2020, the Securities and Exchange Commission Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a ten-page report on examination observations related to cybersecurity and operational resiliency practices taken... [...] Read more
COVID-19 | Does it Change Ad Review and Compliance? Although it may seem like the end of the world right now, regulators continue to operate in business as usual mode particularly with the market volatility and increased messaging to... [...] Read more
February 28 2020
Regulation Best Interest for Advisers Only Regulation Best Interest or Reg BI is a five-page Rule with a 770-page interpretation. Coupled with the 564-page instructions for Form CRS, the average advisor needs to read, understand, and... [...] Read more