UpFront » August 2025

New Congressional legislation is seeking to revise the definition of “accredited investor” from high net worth individuals to anyone that can pass a federally mandated exam. If the legislation is passed by the Senate, it would require the SEC to create either a test or certification within a year. Access to private markets would expand beyond institutional investors and wealthy individuals to many more would-be investors currently not meeting the accredited investor definition, which is…

The North American Securities Administrators Association (NASAA) has issued a proposal on a model rule for states to adapt their marketing and advertising regulations to the SEC’s Marketing Rule. Amy Lynch, FrontLine’s Founder and President thinks that would be a step in the right direction and believes the SEC’s rule has largely been a success. With the lead quotes in the Financial Planning article, Ms. Lynch highlights how the Marketing Rule should be credited with…

Over the course of six years, a New York-based RIA neglected to arrange surprise exams to meet their custody rule requirement. The SEC decided that warranted an enforcement action resulting in a $50,000 fine. FrontLine Compliance Founder and President Amy Lynch comments that it is unusual for this type of violation to go to enforcement. She explains that the firm did not understand the rule applied to them or ignored its requirement, so it never…