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REVERSEinquiries Newsletter, Volume 6, Issue 1 - July 1 2025

An Overview of Which Market Disruption Events to Include for the Most Common Asset Classes under a Medium-Term Note Program - A movie scene showing a day in the life of a calculation agent would likely not survive the...more

FINRA Will Not Set an Effective Date for Amendments to TRACE Rules Establishing One-Minute Reporting Requirement; FINRA to Prepare...

On February 5, 2025, Robert Cook, President and Chief Executive Officer of the Financial Industry Regulatory Industry, Inc. (“FINRA”), announced that FINRA will not set an effective date for its recent amendments (the...more

SEC Grants Temporary Exemption from Rule 13f-2 and Form SHO Compliance

On February 7, 2025, the US Securities and Exchange Commission (SEC) provided a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act and the associated Form SHO reporting. Originally, the...more

ICI Urges SEC to Delay Short-Sell Reporting Rules Amid Compliance Uncertainty

The Investment Company Institute (ICI) has asked the Securities and Exchange Commission (SEC) in a comment letter to delay enforcement of its new short sale disclosure rules (the “Short Sale Final Rules”) until additional...more

2025 SEC Filing Deadlines and Financial Statement Staleness Dates

This Legal Update summarizes the US Securities and Exchange Commission’s 2025 calendar year filing deadlines and financial statement staleness dates....more

FINRA Provides Guidance on Timing Requirements under Certain Broker-Dealer Financial, Operational and Reporting Rules in the Event...

On December 31, 2024, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 24-18 (“RN 24-18”) to provide updated guidance to members regarding Rules 15c3-1, 15c3-3 and 17a-5 under the...more

SEC Division of Examinations Announces 2025 Exam Priorities

On October 21, 2024, the Division of Examinations (“EXAMS” or the “Division”) of the U.S. Securities and Exchange Commission (“SEC”) released its examination priorities (the “2025 Priorities”) for fiscal year 2025 (which...more

Fintech Capital Raising Trends in 2024

Fintech Capital Raising Trends in 2024 - Global capital raising in the fintech sector rose 19% quarter over quarter, while deal volume declined 16%, signaling that investors remain cautious, according to CB Insights’ State...more

The Pendulum Swings Back: FDIC Proposes Changes to Brokered Deposits Restrictions

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s...more

Report: Reforms to Restore Confidence in the SEC

A number of trade associations (The Business Roundtable, the American Investment Council, The Center for Capital Markets Competitiveness of the US Chamber of Commerce, the Investment Company Institute, the Managed Funds...more

SEC Risk Alert:  Staff Assessment of Risks, Scoping of Examinations, and Requesting of Documents

The Division of Examinations (the “Division”) of the Securities and Exchange Commission (“SEC”) recently issued a Risk Alert (the “Risk Alert”) to SEC-registered broker-dealers providing insight and additional information...more

FINRA Reminds Members of Regulatory Obligations When Using Generative Artificial Intelligence (AI) and Large Language Models

On June 27, 2024, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 24- 09 (the “Notice”) reminding member firms that FINRA’s rules and the securities laws apply to the use of artificial...more

DFA Era Incentive-Based Compensation Rule

In recent remarks, Securities and Exchange Commission Commissioner Lizarraga called on the SEC to move forward to implement the rulemaking mandate in Section 956 of the Dodd-Frank Act.  The Commissioner was speaking at an...more

Investment Research

During his remarks at a meeting of the International Bar Association’s Asset Management Industry Conference on Global Challenges and Opportunities in Boston, Commissioner Uyeda commented on investment research and the...more

Commissioner Comments on Tokenization

Commissioner Uyeda spoke at the Securities and Exchange Commission’s 30th Annual Institute for Securities Market Growth and Development. Commissioner Uyeda focused on the need to root out bad actors and promote transparent...more

Frequently Asked Questions for FINRA Member Firms on AI Use in Public Communications

Several days ago, FINRA released guidance updating its Frequently Asked Questions relating to Rule 2210 on Advertising and Public Communications to address Artificial Intelligence.  This follows after FINRA has consistently...more

SEC’s Upcoming Investor Advisory Committee Meeting: Finfluencers and AI

The Securities and Exchange Commission announced an upcoming meeting of its Investor Advisory Committee, which will be held on June 6, 2024.  The agenda includes a number of interesting topics....more

At A Glance: Covered Bonds in 2023

Following the financial sector disruptions in 2023, financial institutions turned first to covered bonds for funding and the covered bond market demonstrated its resilience.  Just as the covered bond market remained available...more

SEC Adopts Rules to Require Registration of Certain Persons Engaging in Liquidity-Providing Activities as “Dealers” and...

On February 5, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted new rules – SEC Rules 3a5-4 and 3a44-2 (collectively, the “Final Rules”) – to further define the phrase “as part of a regular business” used in...more

FINRA Announces Effective Dates for Remote Inspections Pilot Program & Residential Supervisory Location Rules; COVID-19 Relief...

The Financial Industry Regulatory Authority, Inc. (“FINRA”) announced via Regulatory Notice 24-02 (the “Notice”) the effective dates and other important timeframes for new FINRA Rules 3110.18 (Remote Inspections Pilot...more

FINRA Publishes 2024 Annual Regulatory Oversight Report

New Topics and Content Highlight FINRA’s Increased Focus on Cybersecurity, Crypto Assets, Artificial Intelligence, Market Integrity, Off-Channel Communications and Other Key Risk Areas - On January 9, 2024, the Financial...more

Financial Stability Oversight Council 2023 Annual Report

The Financial Stability Oversight Council recently released its annual report.  Not surprisingly, this year’s report reviewed the banking failures in the early part of the year.  In discussing the “vulnerabilities in the...more

SEC Announces 2024 Exam Priorities

On October 16, 2023, the Division of Examinations of the U.S. Securities and Exchange Commission (the “Division” and the “SEC,” respectively) announced its examination priorities for 2024. While the Division typically...more

SEC Significantly Narrows Exemption from FINRA Membership for Proprietary Trading Firms

On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) to Rule 15b9-1 (“Rule 15b9-1”) under the Securities Exchange Act of 1934 (the “Exchange Act”) that generally...more

Ripple is Not a Tidal Wave – the SEC’s Case Against Terraform Labs Provides a Quick Counterpoint to the Recent Ripple Ruling

Just weeks after the novel securities analysis in SEC v. Ripple Labs was handed down by Judge Analisa Torres, a different judge in the Southern District of New York has distinguished the approach taken in Ripple and argued...more

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