With more than 35 years of experience, Steve has not only seen significant changes in the financial services market, but he also has played a key role in shaping the regulatory landscape to accommodate those changes. He participates in the development and regulation of pooled investment vehicles, including mutual funds, other regulated investment companies and private funds, including serving as counsel to funds and fund trustees. Investment advisers and broker-dealers also seek his counsel on regulatory and compliance issues.
Honorable Jesse E. Eschbach, U.S. District Court - Northern District of Indiana.
Awards and Rankings
Recognized as a stand-out lawyer by Acritas Stars: Independently Rated Lawyers (2018)
Recognized by The Legal 500 United States in the area of financial services: regulatory (2015-2018); insurance: non-contentious (2015-2018) and capital markets: equity offerings (2017-2018)
Recognized by Chambers USA: Guide to Leading Business Lawyers in the areas of insurance regulation and investment funds (2008-2018)
Named to The Best Lawyers in America in the area of mutual funds law (2005-2019)
Counseled life insurance companies on the redesign of registered separate account products.
Counseled a coalition of major life insurance companies on evolving state and federal regulations and other legal developments.
Advised on formation and day to day operations of new mutual fund.
“Our insurance clients face many challenges today, but in particular, regulation is clearly very onerous both here domestically and in other countries.”
Legal Alert: The far reach of state law - Nevada proposes fiduciary duty regulations for broker-dealers and investment advisers (January 28, 2019)
Under Nevada law, financial planners owe a fiduciary duty to their clients.1 In accordance with this duty, a financial planner must disclose, at the time advice is given, any gain the financial ...
Legal Alert: SEC investment company filings during government shutdown (January 2, 2019)
The Securities and Exchange Commission (SEC) is subject to the current federal government shutdown due to lack of funding, and generally it will follow its “Operations Plan Under a Lapse in ...
Legal Alert: SEC proposes new variable contract disclosure regime (November 6, 2018)
The US Securities and Exchange Commission (SEC or Commission) recently proposed a new disclosure framework for SEC-registered variable annuity contracts and variable life insurance policies ...
Legal Alert: Standards of conduct for investment professionals - overlapping protections for broker-dealer retirement customers (October 15, 2018)
The legal standards for broker-dealer firms (BDs) and their representatives, particularly in the retirement market, continue to be in flux. BDs were among those most affected by the promulgation in ...
Legal Alert: SEC Staff states that IRS Form 1099-DIV cannot be used to satisfy the requirements of Section 19(a) of the Investment Company Act of 1940 (September 13, 2018)
Section 19(a) of the Investment Company Act of 1940 (the 1940 Act) generally prohibits a business development company (BDC) or a registered investment company from making a distribution from any ...
Legal Alert: SEC permits internet delivery of investment company shareholder reports-including insurance company separate accounts (June 25, 2018)
The Securities and Exchange Commission (SEC) on June 5, 2018, adopted Rule 30e-3 under the Investment Company Act (the Rule), which permits “notice and access” delivery of investment company ...
Legal Alert: The SEC’s proposed rules on the standards of conduct for investment professionals-a quick guide to what you need to know (April 26, 2018)
On April 18, in a 4-1 vote, the United States Securities and Exchange Commission (the SEC) proposed a comprehensive rule set governing the standards of conduct applicable to broker-dealers and ...
The Final Rule: Next Steps After Vacatur (April 5, 2018)
The nationwide vacatur of the Department of Labor “investment advice” fiduciary definition and related exemptions by the US Court of Appeals for the Fifth Circuit on March 15, 2018, does not bring an ...
The Final Rule: DOL Fiduciary Rule Affirmed and Revoked (March 21, 2018)
During the week of March 12, two federal appeals courts separately upheld and vacated the DOL fiduciary rule under the Administrative Procedure Act, and DOL suspended enforcement of the rule pending ...
Legal Alert: Last call! SEC’s pay ratio rule effective for 2018 proxy statements (January 31, 2018)
The long-awaited pay ratio rule (the Rule), adopted by the Securities and Exchange Commission (the SEC) on August 5, 2015, finally takes effect in 2018.1 The Rule, which is intended to provide ...
SEC Offers Relief for Insurers Registering Contracts (December 20, 2018)
For many life insurance companies, the most burdensome aspect of registering insurance contracts that are not investment company securities with the U.S. Securities and Exchange Commission is the ...
Modernizing The Variable Contract Disclosure Regime (December 2018)
The US Securities and Exchange Commission recently proposed a new disclosure framework for SEC-registered variable annuity contracts and variable life insurance policies that reflects almost a decade ...
The Final Rule: DOL’s Expanded Definition of Investment Advice Fiduciary Under ERISA and Revised Complex of Exemptions (April 12, 2016)
Just less than a year since its proposal, and just more than six months after receiving thousands of pages of commentary, petitions and hearing testimony, the Department of Labor finalized its ...
Securities or Not: Uncertainties Remain For Fixed Insurance Products After Dodd-Frank (October 18, 2010)
Reprinted with permission Securities Regulation & Law Report
Navigating the SEC Framework for Registered Non-Variable Annuity Products (June 2010)
The Review of Securities & Commodities Regulation
Reorganizing Insurance Company Separate Accounts Under Federal Securities Laws (1991)
ABA Business Lawyer
Chapter 4: Federal and State Securities Regulation of Annuity Products (July 2017)
Annuities Answer Book - published by Wolters Kluwer
In the fifth edition of the Annuities Answer Book, which provides analysis and commentary on handling the widest variety of annuities issues, Eversheds Sutherland Partner Stephen Roth contributed ...
“If longevity protection can be provided through mutual fund investments, it could greatly expand the availability of lifetime guarantee products to the investing public. It might also offer product solutions that, at least in concept, are relatively simple and cost-effective. However, depending on the product design specifics, there are a number of significant regulatory hurdles that these product concepts must confront.”
35th Annual ALI-CLE Conference on Life Insurance Company Products (November 2-3, 2017)
Join Eversheds Sutherland (US) and ALI for the 35th Annual ALI-CLE Conference on Life Insurance Company Products taking place in Washington, D.C.-again at the Capital Hilton Hotel on November 2-3, ...
Insurance Trends and Emerging Issues CLE Program (September 12, 2016)
Sutherland is proud to host a CLE program focused on Insurance Trends and Emerging Issues on September 12, 2016, in Greenwood Village, Colorado. Topics include Cybersecurity and Technology, Insurance ...
The Evolving Variable Annuity Market (June 7, 2016)
IRI Government, Legal & Regulatory Conference
Sutherland Partner Steve Roth presents The Evolving Variable Annuity Market at the IRI Government, Legal & Regulatory Conference on June 7, 2016, in Washington, DC.
Innovation in the Fixed and Fixed Indexed Annuity Marketplace (June 30, 2014)
Insured Retirement Institute Government Legal & Regulatory Conference
Sutherland Partner Stephen E. Roth presents “Innovation in the Fixed and Fixed Indexed Annuity Marketplace” at the Insured Retirement Institute (IRI) Government, Legal and Regulatory Conference, ...
Insured Retirement Institute (IRI) Litigation Summit (June 18, 2013)
IRI Government Legal & Regulatory Conference
Sutherland invites you to register now for the Insured Retirement Institute (IRI) Litigation Summit on June 18 as part of IRI's annual meeting in Washington, D.C.For the third year, Sutherland is ...
The Securities Status of Fixed Indexed Annuities and Other Products in the Aftermath of the Harkin Amendment and the Withdrawal of Rule 151A (May 14, 2013)
ALIC Annual Meeting
Regulation of Variable Annuity and Variable Life Insurance Products Under the Federal Securities Laws (January 25, 2012)
PLI Securities Products of Insurance Companies and Evolving Regulatory Reform Conference
Fixed Annuity Trends and Issues (May 16, 2011 - May 17, 2011)
Life & Annuity Symposium
Sutherland Partner Stephen E. Roth is presenting at the Life & Annuity Symposium on May 16-17, 2011, in New Orleans, Louisiana. Stephen’s topic is Fixed Annuity Trends and Issues, and the session ...
New Product Strategies (May 5, 2011)
ALI-ABA Collective Trust Funds Current Banking SEC and ERISA Regulatory and Compliance Issues Conference
Sutherland Partner Stephen E. Roth is speaking at ALI-ABA Collective Trust Funds Current Banking SEC and ERISA Regulatory and Compliance Issues Conference on May 5, 2011, in Philadelphia, ...
Selected Regulatory Developments Affecting Variable Insurance Products and Underlying Funds (February 10, 2011)
PLI’s Investment Management Institute
Member, Board of Governors, Association of Life Insurance Counsel (ALIC)
Co-chair, ALI-CLE Conference on Life Insurance Company Products (1999-Present)
Member, ABA Subcommittee on Securities Activities of Insurance Companies
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