In a letter to the Securities and Exchange Commission (SEC), CFA outlined weaknesses in three related SEC regulatory proposals: (1) Regulation Best Interest, which purports to raise the standard of conduct that applies when brokers make securities recommendations (Reg BI); (2) a new interpretive release regarding the standard of conduct for investment advisers (IA Guidance); and (3) a proposal to create a new relationship summary disclosure document for brokers and advisers (Form CRS). Without extensive revisions, these inadequate provisions would leave investors vulnerable to bad advice.
