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SEC Releases Guidance on Robo-Advisers

The SEC recently released guidance on digital advisors, specifically robo-advisers that provide services directly to clients over the internet. However the document noted that the guidance may be helpful for other types of robo-advisers as well as other registered investment advisers. At a recent conference, SEC staff emphasized that the guidance also generally applies to registered investment advisers that do not own a robo-adviser.The guidance confirmed that robo-advisers are subject to the substantive and fiduciary obligations of the Advisers Act and may be subject to certain provisions of the 1940 Act as well and focused on three key compliance areas: disclosures to clients about the robo-adviser and the investment advisory services it offers; information obtained from clients to support the robo-adviser’s duty to provide suitable advice; and compliance programs reasonably designed to address concerns relevant to providing automated advice. 

 
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