Smith & Riley provides legal advice on regulatory and operational matters related to broker-dealers, investment advisers, mutual funds, variable insurance products and bank broker-dealer networking issues. Some key areas of expertise and experience include:

Regulatory

• SEC/state registration of broker-dealers, investment advisers and their agents
• Compliance and supervisory systems, policies and procedures
• Investment adviser code of ethics
• Responses to regulatory deficiency letters and enforcement actions
• Regulatory audits
• Sales practice, suitability and supervision
• Advertising, sales literature and correspondence
• Electronic communications
• Branch and non-branch office issues
• Anti-money laundering programs and compliance
• Gramm-Leach-Bliley: Regulation S-P and bank networking
• Multiple roles: registered representative, investment adviser representative, insurance agent, bank employee
• Life settlement transactions
• ERISA prohibited transaction issues for broker-dealers and investment advisers

Compensation

• Permissible compensation arrangements
• Mutual fund revenue sharing, directed brokerage and other distribution issues
• Disclosure of compensation and conflicts of interest

Operations

• Internal controls
• Recordkeeping
• Clearing arrangements
• Net capital requirements
• Trade reconciliation
• Investment adviser trade allocation

Drafting

• Broker-dealer referral and finder's arrangements
• Investment adviser solicitor agreements
• Investment advisory contracts
• Wrap fee and asset allocation program agreements
• Bank networking program agreements
• Public offering and private placement selling agreements
• Registered representative and employment contracts
• FINRA interpretive and SEC "no-action" letter requests
• FINRA Rule 1017 applications for expansion of business lines
• Disclosures for Form BD, Form U4, Form U5, Form ADV and related schedules