The SEC adopted a rulemaking package designed to
enhance retail investors' protections when dealing with
broker-dealers and investment advisers. The rulemaking package
consists of (i) Regulation Best Interest, (ii) the Form CRS
Relationship Summary, (iii) an interpretation of investment
advisers' fiduciary duty, and (iv) an interpretation of the
"solely incidental" prong of the broker-dealer exclusion
under the
Advisers Act. The rules and forms will become effective 60 days
following publication in the Federal Register, with a transition
period lasting until June 30, 2020. The interpretations will become
effective upon publication in the Federal Register.
Rulemaking Package
Regulation Best Interest ("Reg. BI")
will require broker-dealers not to prioritize their interests ahead
of customers' when making recommendations regarding a
securities transaction, investment strategy or account
recommendation. The regulation provides that a broker-dealer will
satisfy the