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FINRA Re-Proposes Work-From-Home Supervisory Locations

Firms would be able to treat private residences as non-branch offices instead of OSJs under certain circumstances. FINRA hopes to align its supervisory rules with current work-from-home practices....more

SEC Proposes New Regulation Best Execution - Brokers Must Achieve “Most Favorable Price” for Customers; Heightened Obligations for...

The proposal would codify for the first time the federal-level best execution standard for brokers and related obligations. New Regulation Best Execution would result in a pivot from what has been a principles-based approach...more

SEC Examinations Division Publishes 2023 Priorities Letter

The 2023 priorities letter represents only a sliver of the topics firms can expect exam teams to cover this year. In developing the priorities, SEC staff noted their outreach directly to state securities regulators and...more

SEC EXAMS Division Publishes Reg. BI Risk Alert

The risk alert highlights deficiencies the staff identified during examinations and provides examples of weak practices observed at firms. EXAMS staff intends for the alert to assist broker-dealers in reviewing and enhancing...more

SEC Staff Risk Alert Criticizes Broker-Dealer Reports on Best Execution and Payment for Order Flow

The SEC Division of Examinations recently published a Risk Alert on quarterly reports required under Exchange Act Rule 606, which are published by broker-dealers to provide customers with insight into factors influencing...more

FINRA Urges Firms to Focus on Succession Planning

FINRA recently published Regulatory Notice 22-23, providing guidance regarding firm and representative succession planning, including relevant FINRA rules and administrative processes and questions firms can consider when...more

SEC Revamps Broker-Dealer Recordkeeping Requirements; "Audit Trail" Alternative Replaces "WORM" Format

The SEC recently adopted new recordkeeping requirements for broker-dealers and “SBS entities” (security-based swap dealers and major security based swap participants). Most notably, the SEC will no longer require...more

FINRA on Reg. BI Compliance: There is “No One-Size Fits All” Approach

​​​​​​​FINRA recently hosted a conference call with its smaller members covering Regulation Best Interest and Form CRS compliance. FINRA’s resounding message was that there is “no one-size-fits all” approach to Reg. BI...more

Practical Guide to the Application of the Marketing Rule to Private Fund Placement Agents

This article focuses on how the new Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) affects the relationships between investment advisers registered with the U.S. Securities...more

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