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Regulation Best Interest – Is Your Firm Ready?

May Alternative Investment Industry Insights
June 7, 2019
Massachusetts Proposes State Fiduciary Rule; Trade Groups Ask New Jersey to Pause its Process
June 20, 2019

The SEC voted on June 5th 2019 to approve a set of proposals setting new conduct standards for broker-dealers. Regulation Best Interest (“Reg BI”) is part of a package of rules and interpretive guidance directing broker-dealers to act in the “best interest” of their clients. The package also includes new compliance requirements and guidance for both broker-dealers and investment advisers concerning the new obligations owed to retail investors.


The adoption of Reg BI by the SEC marks the start of a very short compliance implementation phase. The SEC stated that the interpretative guidance will be effective upon publication in the Federal Register. (The rules and forms will be effective 60 days later.) Broker-dealers must begin complying with the new rule, and broker-dealers and investment advisers must prepare, deliver to investors, and file the customer relationship summary by June 30, 2020.


Bates Group’s compliance consultants can help your firm through the implementation phase of Reg BI. We help you navigate:
  • Disclosure obligations
  • Duty of care obligations
  • Conflicts of interest obligations
  • Additional compliance obligations
Bates can also assist you with:
  • Developing the new Reg BI Client Relationship Summary (“CRS”) for retail investors
  • Navigating additional compliance requirements for BDs and IAs
  • Understanding new SEC guidance concerning the “Solely Incidental” registration exemption of the Investment Advisers Act
Additional Bates compliance solutions include:
  • Impact and readiness assessments
  • Conflicts of interest inventory
  • Conflicts of interest assessment
  • Product shelf reviews
  • New product approval processes
  • Draft new policies and procedures
  • Data capture and recordkeeping