SEC Rules and Guidance for Investment Advisers Standard of Conduct

Posted by Jessica Forbes and Joanna Rosenberg, Fried, Frank, Harris, Shriver & Jacobson LLP, on Saturday, May 12, 2018 Editor's Note: Jessica Forbes is a partner and Joanna D. Rosenberg is an associate at Fried, Frank, Harris, Shriver & Jacobson LLP. This post is based on a Fried Frank publication by Ms. Forbes and Ms. Rosenberg. On April 18, 2018, following a two-hour open meeting, the U.S. Securities and Exchange Commission (the “SEC”) voted 4-1 to issue the Standards of Conduct for Investment Professionals Rulemaking Package, which is roughly 1,000 pages long and comprises three releases, one of which is a proposed interpretation and two of which are proposed rules regarding the standards of conduct for investment advisers and broker-dealers (each a “Proposal” and together, the “Proposals”). In one release, the SEC proposed an interpretation of the federal fiduciary duty applicable to investment advisers and…

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