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RDB Events
“The SEC’s Regulation of Fee-Based Brokerage Accounts: A Case Study in Administrative Law,” ABA Administrative Law Conference
10/25-26/2007
Merril Hirsh led a discussion of the attempt by the Securities and Exchange Commission to change the regulatory framework for fee-based brokerage accounts through the promulgation of Rule 202(a)(11)-1, exempting certain broker-dealers providing fee-based brokerage accounts from registering with the SEC as investment advisers under the Investment Advisers Act of 1940. In Financial Planning Association v. Securities and Exchange Commission, the D.C. Circuit held in March 2007 that the SEC exceeded its authority when it promulgated that rule.
National Press Club
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