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Regulatory Developments for Dual Registrants  

Author:  Cheryl L. Haas.; Alex M. Madrid.

Source: Volume 52, Number 10, May 15 2019 , pp.113-118(6)

Review of Securities & Commodities Regulation

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As dual registrants have grown in popularity, they currently face increasing regulatory scrutiny from both FINRA and the SEC. The authors discuss the current situation, focusing first on a proposed FINRA rule and then turning to other regulatory issues. They discuss wrap fee programs, conflicts of interest, and best execution. Finally, they detail two issues of particular interest to dual registrants: share class selection and digital investment advice.

Keywords: FINRA Rules 3270 and 3280; Wrap Fee Programs and Reverse Churning; Conflicts of Interest and Best Execution; Share Class Selection; Digital Investment Advice

Affiliations:  1: McGuireWoods LLP; 2: McGuireWoods LLP.

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