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SILA Securities Industry Subgroup (SSIS) Meeting
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SILA Securities Industry Subgroup (SSIS) Meeting

SILA Securities Industry Subgroup Meeting (SSIS) Agenda

When: Tuesday, May 15, 2018
1:00 - 2:00 PM
Where: United States

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SILA Securities Industry Subgroup (SSIS)

2018 – 2nd Quarter


Date:                    Tuesday, May 15, 2018

Time:                    1:00 pm eastern time

Conference #:      303-248-0285 - Code 3405506#


Meeting Agenda


  Welcome – Deirdre Patten, Co-Chair

  1. FINRA Regulatory Notice 17-30 ~ Exam Restructure / Permissive Registration / FSAWP
    1. Principal Operations Officer Designation (potential exam impacts?)
  2. FINRA Regulatory Notice 18-08 ~ Outside Business Activities / Private Securities Transactions
    1. Eversheds Sutherland Comment Letter ~ Interesting comment letter worth reading
  3. FINRA Regulatory Notice 18-14 ~ Retrospective Review of Annual Compliance Meeting
  4. FINRA Regulatory Notice 18-15 ~ Heightened Supervision
  5. FINRA Regulatory Notice 18-16 ~ High Risk Brokers & Firms Than Employ Them
  6. DOL Fiduciary / Conflicts of Interest Update
    1. Highlight the 5th Circuit Mandate (not yet available) / DOL can still appeal to SCOTUS until June 13th (not likely to happen) / intervening motions from AARP and 3 States denied by 5th Circuit / DOL never appealed circuit decision
    2. Department of Labor Field Assistance Bulletin 2018-02 ~ Temporary Enforcement Policy on Prohibited Transactions Rules Applicable to Investment Advice Fiduciaries

Excerpt from 2018-02:  Accordingly, for the period from June 9, 2017, until after regulations or exemptions or other administrative guidance has been issued, the Department will not pursue prohibited transactions claims against investment advice fiduciaries who are working diligently and in good faith to comply with the impartial conduct standards for transactions that would have been exempted in the BIC Exemption and Principal Transactions Exemption, or treat such fiduciaries as violating the applicable prohibited transaction rules.

      7.  SEC Rulemaking Package ~ Not a true ‘fiduciary’ proposal for BDs, but does enhance the standard of care requirement beyond existing ‘suitability’ requirement:

    1. Proposed Regulation Best Interest (Regulation BI)
    2. Proposed Investment Adviser Interpretation
    3. Proposed Form CRS Relationship Summary

8.   Regulatory Notice 17-38 – FINRA proposal to Amend Rule 3110 (Supervision) to provide firms the option to conduct remote inspections of branch offices

9.   SIE Exam Update

10.  FINRA 360 Progress Report

11.  2018 SILA National Education Conference

12.  Securities State Requirements Chart - need for volunteers 

13.  Other topics?

Thank you to our 2018 Sponsors!