If you survey advisors—which many have done—they will tell you that the hardest part of the forthcoming Reg BI rule from the SEC is how to handle all the requirements of the new Customer Relationship Summary form (Form CRS). With that in mind, Pershing has just launched an interesting new end-to-end Form CRS product that helps advisors comply with the rule, as well as a Tracking and Reporting Solution. According to Pershing, “We recognize that account opening is not the only [thing used], so we’ve rolled out a new forms management system where the CRS can be directed and stored digitally, and married that system with a number of trigger points that require the delivery of a Form CRS … We’ve given our clients the opportunity to both deliver forms in paper where it’s still necessary, or digitally to the extent that the investor has opted into electronic delivery”.
FINSUM: Compliance with Form CRS is a challenge, and one that is being exacerbated by COVID and people working from home. This sounds like a great solution.
Smaller broker-dealers around the nation are grossly underprepared for the forthcoming Regulation Best Interest. In early April, the SEC decided not to extend the implementation date of the rule because of COVID, which means all firms will need to be ready by June 30th. However, most small broker-dealers are so focused just trying to stay in business, that most are delaying any actions that will help help for the rule. The SEC has said it will take circumstances into account when enforcing the rule.
FINSUM: One of the big issues besides COVID, is that there is a high degree of complacency about the new rule because many think “I prepared for the DOL rule, so we should be covered for this”. However, there are some important distinctions with this rule (e.g. retail investor vs retail customer), and many could find themselves in hot water.
An update to the SEC’s FAQs page has made something abundantly obvious—the title of “advisor” or “adviser” is about to get a lot more contentious. As part of its new Reg BI package, the SEC is bringing in additional rules around the use of titles. Regarding “advisor”, which is completely ubiquitous, the new rules are pretty clear: you cannot call yourself an “advisor” or “adviser” unless you are registered as an investment advisor. Another important note on this, according to Barron’s, “Broker-dealers that are affiliated with RIAs are generally prohibited from using the terms”.
FINSUM: This is a huge disruption to the lingua franca of the industry, but a big boon to investment advisors. Makes us wonder how much the public will actually care.
New data is out showing which independents are gobbling up the most new recruits in the wealth management space. The overall picture emerging is that while April was a very slow month for changes, Raymond James and LPL are striding ahead of the competition through acquisitions and advisor recruiting. LPL has gotten 59 new recruits to join this year, while Raymond James has managed 20, worth $4 bn and $2.8 bn in AUM respectively. Some usual suspects have been absent so far this year. For instance, Advisor Group has lost more than 25 advisors to LPL in 2020 without announcing a single new advisor joining the network.
FINSUM: LPL and Raymond James have done a great job keeping their recruiting wallets open during this tough time. We expect the relationships they are building right now will keep their pipeline strong for the rest of the year.
The Paycheck Protection Program landscape has been beyond challenging for small business owners. According to COVID Loan Tracker, as of April 30th, only 10.2% of small business owners report actually receiving PPP loans. That compares to the 30% that say they have already received “approval” for the loan by the SBA. That is a huge lag when you are trying to pay employees.
However, for some, that is not even the biggest issue, as just applying itself is a major headache. Not only are the forms one must submit difficult, but many banks won’t let you apply if you are not a customer, so many are stuck in seemingly hopeless queues at giant banks. With that mind, below is a list of sources where you can apply WITHOUT being a customer.
1. COVID Loan Tracker has partnered with Fundera to offer its own PPP app. Applying with online lending platforms like Fundera increases your chances of success because they are connected to a multitude of lenders and only place your application with banks ready to process them. CLT can see in its data that online lending platforms have had very high success rates in getting PPP loans approved.
2. First State Bank: https://1st.bank/ppp/
3. Banc First: https://www.bancfirst.bank/cares/ppp-apply
4. Eastern Bank: https://www.easternbank.com/ppp-request
5. People’s Bank and Trust: https://www.peoples.bank/ppp
6. TCF Bank: https://commercial.tcfbank.com/sbappp/s/application?
COVID Loan Tracker was started by small business owners Duncan and Rita MacDonald-Korth to help their fellow small business owners understand where PPP and EIDL money is flowing. We are empowering the business community and journalists with the data they need to keep the government accountable.
In a stat that should absolutely terrify small broker-dealers, a new survey says that for small firms, Reg BI compliance may cost a large portion of your revenue every year. According to the National Society of Compliance Professionals, a small firm with $500,000 in net capital will need to pay $60,000 a year to comply with the new rule. Bigger firms have high costs too—Raymond James will spend $20m up front, and then another $5m per year to comply.
FINSUM: $60,000 a year is a lot of cost to bear for smaller firms, especially because this regulation does not expand business opportunities and will likely only shrink revenue for many.