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SEC Amends the Customer Protection Rule to Require Daily Reserve Formula Computations for Large Clearing/Carrying Broker-Dealers

On December 20, 2024, the Securities and Exchange Commission (SEC) issued a final rule amending SEC rules 15c3-3 (the customer protection rule) and 15c3-1 (the net capital rule). The SEC also amended Form X-17A-5 Part II (the...more

US District Court Vacates Controversial Dealer Rules

On November 21, 2024, the US District Court for the Northern District of Texas vacated rules adopted by the Securities and Exchange Commission (SEC) in February 2024. Those rules had defined language in the definitions of...more

The SEC Division of Examinations' Fiscal Year 2025 Priorities

On October 21, 2024, the Securities and Exchange Commission Division of Examinations published its examination priorities for fiscal year 2025.1 In this alert, we offer ten observations for broker-dealers. Our observations...more

SEC Modernizes Data Protection Rules for Safeguarding Customer Information

Last month, the Securities and Exchange Commission (the SEC or the Commission) unanimously voted to adopt amendments to Regulation S-P (Reg S-P), which is the SEC’s regulation governing the treatment and safeguarding of...more

FINRA’s 2024 Annual Regulatory Oversight Report: What Broker-Dealers Need to Know

On January 9, 2024, the Financial Industry Regulatory Authority published its 2024 FINRA Annual Regulatory Oversight Report. Previously titled Report on FINRA’s Examination and Risk Monitoring Program, the Report is released...more

SEC Proposes to Expand Reg SCI

The Securities and Exchange Commission (SEC) proposes to amend Regulation Systems Compliance and Integrity (Reg SCI) to update and expand the regulatory oversight of the core technology of the U.S. securities markets.1 The...more

SEC Holiday Reading List: Four Rule Proposals That Would Overhaul Market Structure and How Retail Orders Are Executed

On December 14, 2022, the Securities and Exchange Commission (“SEC” or “Commission”) released four sweeping rulemaking proposals that would change market structure as we currently know it and introduce a new federal standard...more

SEC Proposes New Rules Defining “Dealer” Status: Proposal Seeks to Clarify When Unregistered Firms Engaged in Market-Making and...

On March 28, 2022, the Securities and Exchange Commission (SEC) proposed new Rules 3a5-4 and 3a44-2 under the Securities Exchange Act of 1934 (Exchange Act) (collectively, the Proposed Rules). The Proposed Rules seek to...more

SEC Proposes Significant New Regulatory Obligations for Communication Protocol Systems and Government Securities ATSs

The Securities and Exchange Commission (SEC) proposed significant changes to the regulation of securities trading systems that use non-firm trading interest and alternative trading systems (ATSs) that trade government...more

SEC Issues Investor Alert on Initial Exchange Offerings

On January 14, 2020, the Securities and Exchange Commission’s (“SEC”) Office of Investor Education and Advocacy issued an Investor Alert urging investors to use caution before investing in “initial exchange offerings”...more

The Countdown Is On! Building a Reg BI Compliance Program as Deadlines Loom

On June 5, 2019, the SEC adopted a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with broker-dealers and investment advisers. The focal point of this...more

Regulators Implement Enhanced Oversight and Propose Transparency for the Treasury Market

On October 24, 2016, the Federal Reserve Bank of New York (FRBNY) held a conference on “The Evolving Structure of the US Treasury Market” (Conference). The Conference was a sequel to the first annual such event where...more

SEC's Equity Market Structure Advisory Committee Considers Market Volatility and Customer Issues

The Equity Market Structure Advisory Committee (EMSAC or Committee) held its third meeting at the Securities and Exchange Commission (Commission or SEC) in Washington DC on February 2, 2016. The Committee is considering...more

SEC Proposes Significant Regulatory Changes for Alternative Trading Systems

On November 18, 2015, the Securities and Exchange Commission (“SEC” or “Commission”) proposed significant changes to the regulatory requirements applicable to dark pools and other alternative trading systems (“ATSs”) that...more

Access Fees and Regulatory Structure of Trading Venues

On October 27, 2015, the Equity Market Structure Advisory Committee (EMSAC or Committee) held its second meeting at the Securities and Exchange Commission (Commission or SEC) in Washington DC. The Committee is considering...more

SEC Approves NMS Plan to Implement Tick Size Pilot for Small Cap Stocks

In June 2014, the Securities and Exchange Commission (“SEC” or “Commission”) issued an order directing the national securities exchanges and the Financial Industry Regulatory Authority (collectively, the “Participants”) to...more

Expanding Oversight of Active, Proprietary Trading Firms: SEC Proposes Amendments to Rule 15b9-1

Overview - On March 25, 2015, the Securities and Exchange Commission ("SEC" or "Commission") proposed an amendment to Rule 15b9-1 (the “Proposal”) under the Securities Exchange Act of 1934 ("Exchange Act") that, if...more

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