Eric Arnold is a member of the Sutherland's Financial Services Practice Group, where he focuses his practice on insurance, securities and banking law issues involving the distribution of insurance and investment products by broker-dealers, investment advisers and other financial intermediaries. Eric frequently works with broker-dealer clients to review, revise and update their compliance manuals and procedures. He also regularly advises broker-dealer and investment advisory clients on financial, operational and reporting requirements, including privacy and anti-money laundering issues. On the transactional side, Eric has counseled financial services clients on the rationalization of their distribution structures, which has included providing assistance with consolidating and combining broker-dealer, investment adviser and insurance agency operations in compliance with the applicable regulatory structure. Representative Experience Eric counsels financial services clients in connection with: · Bank, insurance and Internet portal networking arrangements. · Registration issues under federal and state securities laws. · Cash and non-cash compensation programs. · Distribution agreements, principal underwriting agreements and selling agreements. · Structuring and establishing broker-dealers, insurance agencies and investment advisers. Recent Publications and Speaking Engagements · Co-author, "Whither Fee-Based Accounts: The DC Circuit Vacates Investment Advisers Act Rule 202(A)(11)-1" The Investment Lawyer (June 2007) · Co-author, "Final SEC Rule Addressing Broker-Dealer Exclusion from Definition of Investment Adviser," The Investment Lawyer (June 2005) · Author, "Banks Selling Annuities" (Chapter 5), Annuities Answer Book (3rd ed.) (2005 Supplement) · Speaker, Webinar: "Real Estate Funds and Alternative Investments: Impact of Recent FINRA Developments" (March 25, 2010) · Speaker, ALI-ABA Webinar: The Financial Services Regulatory Revolution: Navigating the New World of Broker-Dealer and Investment Adviser Regulation (October 8-9, 2009) · Speaker, "The Federal Regulation of Insurance," New York, NY (June 25, 2009) · Speaker, "Credit Rating Agency Regulatory Developments," 2009 Association of Life Insurance Counsel Annual Meeting (May 3-5, 2009) · Speaker, "Variable Annuities Sales Practices," SIFMA Compliance & Legal Division 2009 Annual Seminar (March 22-25, 2009) · Speaker, Sutherland Securities Symposium (October 30, 2008) · Speaker, Independent Broker-Dealer Regulatory Forum (April 16, 2008) · Speaker, "Variable Annuities-The Distributors' Perspective," SIFMA Compliance & Legal Division 2008 Annual Seminar (March 30 - April 2, 2008) · Speaker, "Variable Annuities-The Distributors' Perspective," SIFMA Compliance & Legal Division 2007 Annual Seminar (March 25-28, 2007) · Speaker, Distributing Separately Managed Accounts Through the Bank Channel: A Guide for Managed Accounts Managers (June 28, 2006) Industries Financial Services Retirement Products and Services News Obama Signs H.R. 4173
July 21, 2010 Legal Alerts Legal Alert: House Subcommittee Approves Bill to Prevent the Federal Insurance Office and Office of Financial Research from Collecting Data Directly from Insurance Companies
December 22, 2011 Legal Alert: ERISA Participant Disclosure Will Not Violate SEC Advertising Rules
November 2, 2011 Legal Alert: FSOC Proposal Further Clarifies Which Nonbank Financial Companies Could Be Designated "Systemically Important Financial Institutions"
October 17, 2011 Legal Alert: SEC Adopts Extensive Changes to Investment Adviser Regulatory Scheme as Mandated by the Dodd-Frank Act
June 23, 2011 Legal Alert: NAIC Releases Draft White Paper On Corporate Governance; At Odds With Existing Bodies of U.S. Law
June 10, 2011 Legal Alert: FSOC Proposed Rulemaking on Fed Supervision of Nonbank Financial Companies: Congress Questions Transparency
May 23, 2011 Legal Alert: New York Department of Financial Services to Have Authority Beyond Legacy Regulators; New Legal Risks Emerge for Insurers
April 27, 2011 Legal Alert: FINRA Delays Implementation of New Suitability Rules Until July 2012
April 11, 2011 Legal Alert: The Consumer Financial Protection Bureau: Structure, Mission and Limitation of Authority Prior to the Appointment of a Director
March 8, 2011 Legal Alert: FSOC Proposed Rulemaking on Fed Supervision of Nonbank Financial Companies: Critics Submit Comments and Ask Who is Speaking on Behalf of the Insurance Industry
March 7, 2011 Legal Alert: The Financial Stability Oversight Council Takes Action: New Insight into Determination of Which Insurers May Be Subject to Enhanced Oversight
February 18, 2011 Legal Alert: DOL Advisory Opinions Consider Fiduciary Issues
February 16, 2011 Legal Alert: Significant Changes to FINRA's Know Your Customer and Suitability Rules to Take Effect in 2011
January 3, 2011 Legal Alert: Broker-Dealer Annual Audits and Accounting Standards: SEC and PCAOB Developments
December 21, 2010 Legal Alert: New York's Highest Court Approves STOLI Policy Sales
November 18, 2010 Legal Alert: DOL Finalizes New ERISA Disclosure Rules for Participant-Directed Retirement Plans
October 20, 2010 Legal Alert: The Financial Stability Oversight Council Holds Inaugural Meeting; Proposed Rulemakings on Nonbank Financial Companies and the Volcker Rule Will Impact Insurers
October 13, 2010 Legal Alert: Impact of Dodd-Frank Wall Street Reform and Consumer Protection Act on Broker-Dealers
August 16, 2010 Legal Alert: The Dodd-Frank Act: A New Era of Financial Regulation and the Implications for the Insurance Industry
August 3, 2010 Legal Alert: NAIC Proposes Expansive New Governance, Risk Management and Reporting Duties on Insurance Holding Company Systems; A New Liability Profile Emerges for Directors and Senior Management
July 9, 2010 Legal Alert: Class Certified in Action Involving Annuity Sales to Seniors
June 30, 2010 Legal Alert: FINRA Issues Guidance for Broker-Dealers Participating in Private Offerings
April 29, 2010 Legal Alert: House Holds Hearing on Insurance Holding Company Supervision
March 19, 2010 Legal Alert: The Dodd Bill Redux: The Senate Takes Aim at Financial Regulatory Reform
March 19, 2010 Legal Alert: FINRA Proposes to Include More and Older Information on BrokerCheck
February 24, 2010 Legal Alert: Obama Administration Proposes Financial Crisis Responsibility Fee
January 15, 2010 Legal Alert: FINRA Restricts Internal Use Only Rules Through Enforcement Actions
January 6, 2010 Legal Alert: SEC Adopts Amendments to Advisers Act Custody Rule
December 17, 2009 Legal Alert: Proposed Federal Insurance Office Act of 2009 Moves Forward
December 4, 2009 Legal Alert: NAIC Proposes Federal Legislation That Could Reduce Reinsurance Collateral Requirements
October 16, 2009 Legal Alert: NAIC Life Insurance and Annuities (A) Committee Approves Revisions to Standard Valuation Law to Enable Principles-Based Reserving
September 10, 2009 Legal Alert: Ninth Circuit Overturns Denial of Class Certification in Action Involving Sale of Annuities to Senior Citizens; Orders Class Certified
August 31, 2009 Legal Alert: Impact of Financial Regulatory Reform on the Insurance Industry: Proposed Legislation to Implement the Regulatory Reform White Paper
August 5, 2009 Legal Alert: Suitability, Solvency Modernization, International Accounting and Derivatives: The NAIC 2009 Summer Meetings
June 30, 2009 Legal Alert: Financial Regulatory Reform - A New Foundation: Building Financial Supervision and Regulation
June 19, 2009 Legal Alert: Sutherland Finds That FINRA Sanctioned Far Less in 2008 Than in Previous Three Year
June 3, 2009 Legal Alert: SEC Issues Release Proposing Amendments to Rules Governing Custody of Client Assets by Investment Advisers
May 27, 2009 Legal Alert: Recent Developments: The Federal Regulation of Insurance
May 19, 2009 Legal Alert: National Insurance Consumer Protection Act and Prospects for Federal Regulation of Insurance
April 13, 2009 Legal Alert: Optional Federal Charter Bill Introduced in House
April 3, 2009 Legal Alert: Highlights From the 2009 SIFMA Legal and Compliance Annual Seminar
April 3, 2009 Legal Alert: Sutherland to Host Webinar on FINRA Sweep of Sales and Promotion of Non-Traded REITs
March 30, 2009 Legal Alert: Investment Adviser Developments: SEC Chairwoman and Treasury Secretary Offer Proposals for Regulatory Reform
March 27, 2009 Legal Alert: Senate Banking Committee Hears Testimony on Insurance Regulation
March 18, 2009 Legal Alert: Federal Insurance Regulation: An Updated Scorecard
March 12, 2009 Legal Alert: Regulation D Developments
March 5, 2009 Legal Alert: State Securities Regulators Propose an Agenda for Change, Will Not Take the Financial Crisis Lying Down
February 9, 2009 Legal Alert: A Scorecard on the Systemic Risk Regulator and Federal Insurance Regulation
February 9, 2009 Legal Alert: NAIC Executive Committee Rejects Emergency Action on Capital and Surplus Relief
January 30, 2009 Legal Alert: Insurance Industry Capital and Surplus Relief Proposal Gains New Life
January 28, 2009 Legal Alert: House Members Encourage the Creation of a National Insurance Office Within Treasury
January 26, 2009 Legal Alert: Sutherland to Host Webinar on FINRA Sweep of Broker-Dealer Referrals of Investment Advisory Services
January 26, 2009 Legal Alert: Access to TARP Program and Fed Funding: Insurance Company Strategies and Implications
January 14, 2009 Legal Alert: Obama Places High Priority on Restructuring the Nation's Financial Regulatory System
December 19, 2008 Legal Alert: Recent Developments Relating to Insurance Company Participation in the Treasury's TARP Program
November 19, 2008 Legal Alert: House Financial Services Subcommittee Approves the Insurance Information Act of 2008 to Create an Office of Insurance Information
October 10, 2008 Legal Alert: Issues List for Broker-Dealers Responding to Financial Markets Events
October 9, 2008 Legal Alert: Impact of the Emergency Economic Stabilization Act and Related Developments on Insurance Companies
October 7, 2008 Legal Alert: Moving Forward with the Bailout - The Emergency Economic Stabilization Act of 2008 Becomes Law
October 3, 2008 Legal Alert: State Securities Regulators Discuss Developments and Initiatives
October 2, 2008 Legal Alert: Progress on the "Bailout" Proposal - The Senate Passes an Expanded Emergency Economic Stabilization Act of 2008
October 2, 2008 Legal Alert: The Evolving "Bailout" Proposal - Emergency Economic Stabilization Act of 2008
September 29, 2008 Legal Alert: Warnings About Replacing AIG Policies
September 29, 2008 Legal Alert: Sutherland to Host Conference Call on FINRA Sweep Examination of Auction Rate Securities
August 22, 2008 Legal Alert: FINRA Spring Securities Conference
June 23, 2008 Legal Alert: Sutherland Forms Regulatory Reform Task Force
June 12, 2008 Legal Alert: Is There a "Good Faith" Defense to Securities Fraud? Courts, the SEC and FINRA in Conflict
April 29, 2008 Legal Alert: Form ADV Part 2 Proposal
March 13, 2008 Legal Alert: FINRA Tells Members to Revisit Customer Statement and Web Site Descriptions of Auction Rate Securities Backed by Fixed Income Products and Temporarily Increases Maintenance Margin for Such Securities
March 6, 2008 Legal Alert: SEC Proposes to Amend Regulation S-P to Require New Client Information Safeguards and Allow Reps to Take Certain Client Information When They Change Broker-Dealer or Investment Adviser Firms
March 5, 2008 Legal Alert: Rulings on Class Certification, Expert Testimony and Summary Judgment in Case Involving Sales of Annuities for Qualified Retirement Plans
February 18, 2008 Legal Alert: FINRA Proposes Significant Changes to IM-3060 on Gifts and Entertainment
January 22, 2008 Legal Alert: SEC Posts RAND Corporation Report on Investment Adviser and Broker-Dealer Industry
January 9, 2008 Legal Alert: MSRB Notice 2007-32 - New Supervisory Requirements Under Rule G-27
November 13, 2007 Legal Alert: Sutherland to Host Conference Call on FINRA Sweep Examination of Life Settlements
November 13, 2007 Legal Alert: FINRA Fall Securities Conference
October 25, 2007 Legal Alert: Sutherland Study Finds That It Sometimes Pays to Litigate Against FINRA (Formerly NASD)
September 27, 2007 Legal Alert: Sutherland to Host Conference Calls on FINRA Sweep Examination of the Use of Professional Designations Involving Seniors and Retirees
September 12, 2007 Legal Alert: SEC Adopts Rule Prohibiting Fraud by Advisers to Certain Pooled Investment Vehicles
August 6, 2007 Legal Alert: FINRA Conducting a Sweep Examination of Pitches to Retirees and Section 72(t) Withdrawals
August 3, 2007 Legal Alert: NASD and NYSE Request Comments on Proposed Guidance Regarding Supervision of Electronic Communications
June 29, 2007 Legal Alert: NASD Answers Frequently Asked Questions Regarding SEC Financial Responsibility Rules
April 12, 2007 Legal Alert: Summary of Selected Programs from SIFMA Compliance & Legal Division's 2007 Annual Seminar
April 3, 2007 Legal Alert: NASD Provides Guidance and Mandates Additional Procedures for Firms' Supervision of Representatives Transferring from Other Firms
February 21, 2007 Publications Whither Fee-Based Accounts: The DC Circuit Vacates Investment Advisers Act Rule 202(A)(11)-1
June 2007 The Investment Lawyer Final SEC Rule Addressing Broker-Dealer Exclusion from Definition of Investment Adviser
June 2005 The Investment Lawyer "Banks Selling Annuities," (Chapter 5), Annuities Answer Book, (3rd ed.) (2000) Events The Financial Services Regulatory Revolution: Navigating the New World of Broker-Dealer and Investment Adviser Regulation
September 23, 2011 BDC Quick Call: Recent Accounting and Regulatory Developments on Advisory Fees and Financing Transactions
March 3, 2011 Fiduciary Duty Forum
July 28, 2010 Webinar - Real Estate Funds and Alternative Investments: Impact of Recent FINRA Developments
March 25, 2010 The Financial Services Regulatory Revolution: Navigating the New World of Broker-Dealer and Investment Adviser Regulation
October 8-9, 2009 The Federal Regulation of Insurance
June 25, 2009 2009 Association of Life Insurance Counsel Annual Meeting
May 3-5, 2009 Securities Industry and Financial Markets Association (SIFMA) Compliance & Legal Division 2009 Annual Seminar
March 22-25, 2009 Sutherland Securities Symposium
October 30, 2008 Independent Broker-Dealer Regulatory Forum
April 16, 2008 SIFMA Compliance & Legal Division 2008 Annual Seminar
March 31-April 2, 2008 SIFMA Compliance & Legal Division 2007 Annual Seminar
March 25-28, 2007 SIA-CL Annual Seminar
Sunday, March 25 - Wednesday, March 28, 2007 Distributing Separately Managed Accounts Through the Bank Channel: A Guide for Managed Accounts Managers
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