300 Montgomery Street, Suite 600

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Presentation transcript:

300 Montgomery Street, Suite 600 WRAP PROGRAMS What Sayeth the SEC? Stephen P. Wilkes, Esq. 300 Montgomery Street, Suite 600 San Francisco, CA 94104 415-625-0002 swilkes@wagnerlawgroup.com

Agenda Introduction SEC Focus Program Structuring • Who Participates • Disclosures • Marketing • Sponsor and Manager Issues • Rule 3a-4 • Trading Away • Suitability • ERISA • Other Issues SEC Enforcement Activity

Introduction Evolving continually in marketplace Significant growth SMA, UMA, TPAM (FA to third party) Asset Allocation Programs, Mutual Fund Programs, Target Date Programs, Mini Accounts, Proprietary v Non Proprietary; Overlay Programs, etc. Bundle services and /or managers – single fee Many special rules and complexities – e.g., Form ADV rules, confirms, Rule 3a-4, ERISA

SEC and FINRA and State Focus Under scrutiny – often cited for target enforcement or investor advisory Investor Bulletin, December 7 2017, SEC Reverse churning Consider program features and advantages Trading away Adequate disclosure Fee reasonableness

Program Structure Parties Sponsor, Adviser, Manager: What do they do? Legal status? Disclosure, Confirms, Marketing Rule 3a-4/Investment Company Act , Securities Act Trading Suitability Fees/Compensation ERISA

SEC Enforcement Activity Areas of interest: Suitability Conflicts Fee reasonableness, reverse churning Disclosure Best Execution Proprietary product

SEC Enforcement Activity Raymond James & Associates AIG Barclays Robert W. Baird & Co. WFG Advisors, LP Stifel Nicolaus & Co. JP Morgan Riverfront Investment Group

Important Information This presentation is intended for general informational purposes only, and it does not constitute legal, tax or investment advice from The Wagner Law Group.

300 Montgomery Street, Suite 600 WRAP PROGRAMS What Sayeth the SEC? Stephen P. Wilkes, Esq. 300 Montgomery Street, Suite 600 San Francisco, CA 94104 415-625-0002 swilkes@wagnerlawgroup.com