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SEC’s Division of Examinations Releases 2023 Examination Priorities

Each year, the SEC’s Division of Examinations (the “Division”) releases its priorities for the upcoming year, providing SEC registrants with a helpful tool to assist in managing, reviewing, and updating their compliance...more

SEC's Division of Examinations Releases 2022 Examination Priorities

Each year, the SEC’s Division of Examinations (the “Division”) releases its priorities for the upcoming year, providing SEC registrants with a helpful tool to assist in managing, reviewing, and updating their compliance...more

SEC Assesses Nearly $1 Million in Fines for RIAs and BDs’ Failure to Deliver Form CRS

Yesterday, the U.S. Securities and Exchange Commission (“SEC”) announced that it has entered final administrative orders against 21 registered investment advisers (“RIAs”) and six broker-dealers (“BDs”) for failing to file or...more

New FINRA Filing Requirements for Private Placement Recommendations; More Private Offering Regulatory Restrictions Likely

FINRA Rules - On July 15, 2021, FINRA announced that it has updated its rules regarding the offering of private placement securities to expand the existing requirement that each broker-dealer that issues and/or sells a...more

Iowa Proposes State-Specific Best Interest Rules for Insurance and Securities Businesses (Updated)

UPDATE: As of December 30, 2020, Arizona, Arkansas, Michigan, and Rhode Island have joined Iowa in adopting the NAIC model rule for best interest standard in annuity sales. Alabama, Delaware, Kentucky, Maine, Nevada and Ohio...more

Key Take-Aways from SEC Roundtable on Regulation Best Interest and Form CRS

The Securities and Exchange Commission ("SEC") staff hosted a roundtable with the Financial Industry Regulatory Authority ("FINRA") on October 26, 2020, to discuss their observations on the implementation of, and compliance...more

The New York AG Estimates Rule Proposals Would Impact up to 14000 IARs 5500 Issuers

On April 15, 2020, the Investor Protection Bureau of the New York Department of Law (a division of the attorney general’s office) (the “Bureau”) published proposed amendments to regulations governing state-registered...more

Iowa Proposes State-Specific Best Interest Rules for Insurance and Securities Businesses

UPDATED: MAY 12, 2020: Yesterday, Iowa adopted its proposed regulation requiring annuity agents to act in the best interest of consumers, but delayed adoption (or revision, withdrawal) of the companion securities rules. The...more

Massachusetts Adopts Amendments to its Fiduciary Rule Part II The Massachusetts Fiduciary Rule and Reg BI

On February 21, 2020, the Massachusetts Securities Division (the “MSD”) announced the finalization of its fiduciary rule. Part I summarized the evolution of Massachusetts Fiduciary Rule (“Fiduciary Rule”) and the...more

Regulators Issue Senior Safe Act Fact Sheet

To mark the one-year anniversary of the passage of The Senior Safe Act (the “Act”), the Securities and Exchange Commission (“SEC”), the North American Securities Administrators Association (“NASAA”), and the Financial...more

Regulators Focus on Vulnerable Seniors Advisers and Brokers On Notice

On Tuesday, the U.S. House of Representatives passed the “National Senior Investor Initiative Act of 2019” (H.R. 1876) (the “Act”), which directs the U.S. Securities and Exchange Commission (“SEC”) to establish a taskforce...more

FINRA Issues Guidance Re Customer Communications on Departing Registered Reps

Last week FINRA issued guidance (Regulatory Notice 19-10) with respect to communications with customers about registered representatives (“RRs”) who have left a broker-dealer (the “Notice”). With increased frequency, RRs...more

Investment Management Regulation: Year in Review

As we prepare for a new year of regulatory initiates and actions, we believe it is important to take inventory of the most significant regulatory events from the past year. True to its word, the SEC focused on reducing...more

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