The rules, as they pertain to RIAs, are essentially a reaffirmation of behavior that already is acknowledged in the industry plus a few clarifications, says Jim Lundy, a partner in Drinker Biddle & Reath LLP’s Chicago office and a securities lawyer.
“The takeaway is this is not new guidance,” he says. It reaffirms aspects of fiduciary duty that are spelled out under Section 206 of the Investment Advisers Act. But the words “fiduciary duty” never appear in the advisers act, he adds.
‘Enforcement 40’ for 2020
Join Us On LinkedIn
Join the Securities Litigation and Enforcement Group on LinkedIn