Here are issues FSI has recently been involved in with regulators:
Additional Regulation on Annuity Sales Contemplated in Kentucky On February 21, 2012, FSI submitted a letter urging the Kentucky Legislature to carve our deferred variable annuities from House Bill 173 (H.B. 173). Branch Office Registration Issues in the State of Florida Over the past several months, FSI has been working with the state of Florida to improve approval times of broker-dealer and investment adviser branch office applications. Florida regulators recently provided a list of “common issues that may delay a branch office application.” Building Relationships with State Regulators FSI staff and members recently had the opportunity to meet with state regulators in Missouri and Massachusetts to introduce FSI and to share the concerns of independent broker-dealers and our industry. California Independent Contractor Bill Equates to Additional Costs for Advisors If enacted into law, Senate Bill 459 (Corbett) will increase your costs by requiring independent broker-dealers to give all independent contractor financial advisors an additional statement that explains the advisor’s status as an independent contractor, and would require the broker-dealer to maintain these records for a prolonged period. California Independent Contractor Withholding Proposal In an effort to address California’s severe budget crisis, the state legislature has considered raising funds via an onerous 3% withholding tax on payments to independent contractors by businesses and public agencies. Call to Action – Oppose IL Effort to Eliminate 403(b) Market Competition The Illinois legislature has introduced a bill (HB 5495) that would, in effect, require public school districts to eliminate investment options in their 403(b) plans. Coalition Letter in CA 6.23.11 Comment Letter on California’s Private Adviser Proposal On February 8, 2012, FSI commented on the California Department of Corporations (DOC) proposed amendments to Section 260.204.9 of Title 10 of the California Code of Regulations. Comment Letter on Proposed GASB Fee Seeks Higher Exemption Threshold February 15, 2012
FINRA has recently proposed a rule to adopt a new Section 14 to Schedule A of the FINRA by-laws which would establish an accounting support fee designed to fund the annual budget of the Governmental Accounting Standards Board (GASB).
Constructive and Effective Engagement with NASAA on Model Rule for Private Fund Advisor July 20, 2011
One of FSI’s top priorities is to continually build strong relationships with state securities regulators on behalf of our members. FSI first commented on NASAA’s Model Rule for Private Fund Advisors in February, then again in early July. Our constructive engagement with NASAA has paid off as NASAA’s Board has accepted our recommendation to hold off on finalizing its Model Rule until the SEC adopted final amendments to the Investment Advisor Act of 1940 (Advisers Act) – which happened on June 22.