The SEC’s own Investor Roundtables clearly demonstrate that not even well-educated professionals can understand Form CRS.
In 2016 and 2017, the Consumer Federation of America reported in three separate comment letters that 34 financial firms changed their products and/or product offerings to comply with the DOL Fiduciary Rule. They did so against a backdrop of industry criticism that the Rule would be harmful not only to their own business models, but to their customers and clients as well. Some of the very same firms heftily contributed to that backdrop. However, in announcing their new products and offerings, many of these same firms reversed their position on the impact on investors. Now, they believe such changes are overdue, prudent, and beneficial to customers. Why the switch? And will such product improvements survive the recent vacatur of the DOL Rule? Time will tell.
The SEC will have an open meeting on Wednesday, April 18, 2018, to vote on and release a proposed rule on conduct standards for brokers and advisers. The Institute has submitted two comment letters and met with commissioners and staff. Here is a brief on what we expect and will look for regarding a standard for brokers and title reform.
By Darren M. Fogarty — The mere presence of an observer, while an individual is reading a disclosure, can impede their ability to make informed decisions, while mandatory waiting periods have a positive effect on consumers’ ability to make informed decisions.
The Board has a unique opportunity to set a true fiduciary standard, and seize the moment to benefit generations to come. In the attached letter to the SEC from the Institute, we provide further steps and protocols to manage and neutralize conflicts impact. We urge the Board to apply them.
Adviser and Broker Dealer Standard of Conduct: For generations, the Advisers Act of 1940 has served well as a “contract” between advisers and their clients. The Commission’s rulemaking here effectively puts this “contract” under review and renewal.