On June 5, 2019, the Securities and Exchange Commission adopted, by a 3-1 vote, Regulation Best Interest (“Reg BI”) which, in the words of Chairman Clayton, would “substantially enhance the broker-dealer standard of conduct beyond existing suitability obligations.” The Chairman also noted: “the standard of conduct draws from key fiduciary principles and cannot be satisfied… Continue Reading
During a recent webinar sponsored by the Washington Legal Foundation, we explored the impacts intensive individual-focused criminal enforcement can have on an industry, using the recent history of criminal enforcement of food safety laws as a case study. The individual prosecutions we discussed in that context were based in large part on application of the… Continue Reading
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