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Four Lessons from Two FINRA Enforcement Actions against Crowdfunding Portals

On May 4, 2022, FINRA announced that it had fined two FINRA-registered funding portals a combined $1.75 million for failing to comply with securities laws and rules designed to protect crowdfunding investors. Funding portals...more

FINRA Reminds Firms of Evolving Definition of “Prompt” Order Execution

FINRA recently reminded firms of their obligation to execute marketable customer orders fully and promptly. While this seems fairly routine, what’s notable about the reminder is that “prompt” doesn’t necessarily mean what it...more

Regulation Best Interest and Form CRS: Spotlight on FINRA’s 2022 Exam and Risk Monitoring Program Report

This is the first in a series of alerts discussing topics covered by FINRA in its 2022 Examination and Risk Monitoring Program Report (the “Report”). Here we take a look at Regulation Best Interest (“Reg. BI”) and Form CRS,...more

FINRA to Permit Temporary Transaction Holds and Longer Disbursement Holds to Prevent Financial Exploitation of Elders and Other...

FINRA Rules 2165 (Financial Exploitation of Specified Adults) and parts of 4512 (Customer Account Information) became effective on February 5, 2018 and implemented a framework to permit broker-dealers to place a temporary...more

FINRA Publishes 2022 Examination and Risk Monitoring Report

On February 9, 2022, FINRA published its 2022 Report on its Examination and Risk Monitoring Program, identifying key areas of focus for broker-dealer exams this year. While each exam is unique to the firm under FINRA’s...more

SEC Proposes Securities Lending Transaction Reporting Requirements

On November 18, 2021, the U.S. Securities and Exchange Commission proposed new Rule 10c-1, which, if adopted, would create a new reporting and disclosure framework for the securities lending market. Rule 10c-1 would require...more

FINRA Extends the Registration Qualification Window from Two to Five Years After Termination

Persons registered with a broker-dealer historically have had two years from their Form U5 filing date to re-register with another firm before their prior qualifications (examinations) would lapse. This two-year window often...more

FINRA Adds Continuing Membership Application Requirement to Address Brokers With a History of Misconduct

FINRA recently amended its rules in order to strengthen its tools to respond to brokers with a significant history of misconduct and the firms that employ them. The amended rules include FINRA’s Disciplinary Proceedings...more

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