Despite the disruptive effect of COVID-19, the SEC does not intend to extend the effective dates for compliance with Reg. BI and Form CRS. In addition, the SEC’s Office of Compliance Inspections and Examinations recently announced its intention to begin examinations of registrants’ implementation of these new regulations. Such examinations are expected to occur during the first year after the effective dates. The Financial Industry Regulatory Authority (FINRA) also announced its intent to follow a similar approach with respect to examinations of broker-dealers, focusing on whether firms are making a good faith effort to establish and implement policies and procedures reasonably designed to ensure that a broker-dealer complies with Reg. BI and Form CRS.

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