With broker-dealers now faced with Regulation Best Interest (Reg BI), moving to the dual registrant model seems like a viable solution to resolve the onerous task of overhauling marketing materials, as well as other firm and individual branding relying on the term “advisor.” However, FrontLine’s Founder and President, Amy Lynch, says not so fast. Ms. Lynch cautions that dual registrants have two different sets of regulations to comply with and a broker-dealer compliance program will not suffice in meeting Investment Adviser Act requirements, nor SEC adviser exams. She adds that the new dual registrant will need to build out an investment adviser compliance program, which will require expertise in how the rules impact the firm’s business and supervision of its employees. See Financial Advisor IQ, “B-Ds Face Marketing Challenge in Light of SEC Stance on Advisor Title“
