9 pages. "As a general theme, the exemptions differentiated a recommendation from general communication where a recommendation is deemed to be investment advice and subjects the advisor to be a fiduciary. Responsibilities are placed on the advisers intending to use an exemption to know or reasonably believe that the counterparty is a fiduciary.... An investment platform (which is often affiliated with or a part of recordkeeping services and asset managers) can avoid being considered offering recommendations if the communication is not individualized and clearly discloses in writing that the platform is not a fiduciary and should not be deemed as offering impartial investment advice."

MORE >>