White Papers

SEC Regulation Best Interest History and Adoption of Final Regulation.

To study the regulation thoroughly and provide meaningful interpretation and guidance, this paper will be presented in a series of three parts. I begin, in this paper, with a brief review of the history and development of Regulation Best Interest and a broad overview of the General Obligations it imposes on Broker/Dealers. The next edition will explore Form CRS, in depth, and the final edition will explain the Commission’s reinterpretations of the Fiduciary Obligations of RIA’s and the “Solely Incidental” exemption for broker/dealers.

Valuation of Fee Based Advisory Accounts
Is the Traditional Approach Dead?

In the past, the value of a Financial Advisor’s (advisor) practice was primary based on total assets under management and recurring revenues. It was almost purely a quantitative approach and it assumed among other things

Selling Annuities Post DOL Rule

Threats to Brokerage General Agency and Independent Agents

The Broker General Agent (BGA), sometimes referred to as Managing General Agent (MGA), acts as an independent firm or contractor working for numerous insurance companies whose main function is to support the sale of one or more insurance products by select insurance brokers/agents (producers). Producers then sell the policies to their clients. BGA’s can
specialize in one segment of the insurance industry, or sell policies across a wide range of companies and products including fixed annuities, fixed index annuities and non-variable forms of life insurance.


A Fair and Balanced View

Whether a fan or critic, expert or novice, it is generally agreed that annuities are complex financial instruments whose features, architecture and costs make them among the most difficult to understand. Promoters of annuities naturally portray them as simple and safe investments coupled with valuable guarantees that insure against loss of principal and longevity
risk thus providing peace of mind and guaranteed income in retirement. On the other hand, opponents will present elaborate quantitative studies that attempt to demonstrate that annuities are extremely inefficient investments whose “guarantees” come at an unreasonable cost and sacrifice of liquidity.

Financial Services Industry

Regulatory Reform and Arguments of Standards

The system of regulation of Financial Services in the U.S. is seen as one of the most complex and comprehensive to be found in the world. Indeed the rules and regulations promulgated by FINRA and the SEC are emulated by many countries in Europe and Asia that have advanced financial markets. Ours is arguably the most advanced regulatory structure and the benchmark to which others would be compared.

6 Steps to Compliance with the DOL Fiduciary Rule or a Uniform Fiduciary Standard

This treatise is designed to provide all financial advisers with practical guidance to achieving compliance with a fiduciary standard of care regardless of their specialty within the financial services industry. It explores six essential elements required to meet a fiduciary standard of care including the Department of Labor Fiduciary Rule (the DOL Rule). In addition, it can serve as “buyers guide” for the public consumer of financial services.