Rob Salkowitz is author of Comic - Con and the Business of Pop Culture (McGraw - Hill, 2012), Young World Rising (2010), and two other books on youth and digital
media as agents of change.
Comments received by the Department and
media reports also indicate that many financial institutions already had completed or largely completed work to establish policies and procedures necessary to make the business structure and practice shifts required by the Impartial Conduct Standards earlier this year (e.g., drafting and implementing training for staff, drafting client correspondence and explanations
of revised product and service offerings, negotiating
changes to agreements with product manufacturers
as part
of their approach to compliance with the PTEs,
changing employee and
agent compensation structures, and designing conflict - free product offerings), and the Department believes that financial institutions may use this compliance infrastructure to ensure that they meet the Impartial Conduct Standards after taking the additional Start Printed Page 16910sixty days for an orderly transition between June 9, 2017, and January 1, 2018.