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Does the SEC Expect Investment Advisers to Make a Sweeping Compliance Upgrade?
Cohen & Buckmann, P.C. Link to more items from this source
Oct. 14, 2019

"[T]he Interpretation includes discussion of institutional clients, stating that the level of fiduciary duty for an institutional or more sophisticated investor may be different than that for an individual investor. Though REG BI may not apply to internal Pension Fiduciaries, it will apply to [investment advisers] handling 401(k) rollovers, not just with respect to investment advice, but also with respect to the advice to roll over the 401(k)."

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