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Ending the Remain in Mexico Program: Judging the Boundaries of Executive Discretion

SEC Investment Advisers: Texas says April Fools! to Federal Preemption? | Winstead PC

To embed, copy and paste the code into your website or blog: On April 1, 2021, the Texas State Securities Board (TSSB) announced the entry of a Consent Order against an SEC registered investment adviser named Independent Financial Group, LLC (“Independent”). The TSSB’s action may represent a large shift in investment adviser regulation and enforcement considerations for SEC-registered investment advisers.  (Emphasis on “may.”) The Investment Advisers Act of 1940 is commonly understood to significantly limit states’ application of their securities laws as to SEC registered investment advisers. Specifically, Section 203A(b) of the Investment Advisers Act states that “No law of any State or political subdivision thereof requiring the registration, licensing, or qualification as an investment adviser…shall apply to any person” that is registered with the SEC. However, Section 203A(b) goes on to confirm that the preemption discussed in the subsection will not prohib

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