The Securities and Exchange Commission (the "SEC" or "Commission") has adopted new rules that further define the phrase "part of a regular business" for purposes of determining whether a person is a "dealer" or "government...more
2/28/2024
/ Dealers ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Adviser ,
New Rules ,
Registration Requirement ,
Securities and Exchange Commission (SEC) ,
Securities Dealers ,
Securities Exchange Act ,
Securities Exchange Act of 1934 ,
Securities Regulation ,
Securities Traders ,
Securities Transactions
The Situation: Title II of the Dodd-Frank Act created an insolvency framework for the orderly liquidation of large financial companies, including SEC-registered broker-dealers, if certain financial distress and systemic risk...more
On August 5, 2020, FINRA published Regulatory Notice 20-26, summarizing the results of a survey FINRA conducted of a representative cross-section of member firms, including firms with significant trading volumes or positions...more
The situation: Investors are increasingly focused on environmental, social, and governance ("ESG") factors when opening investment accounts and/or making investment decisions.
The result: Most guidance regarding ESG...more
The Situation: The U.S. Securities and Exchange Commission's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") issued its 2020 examination priorities ("Exam Priorities").
The Result: The Exam Priorities...more
1/27/2020
/ Anti-Money Laundering ,
Broker-Dealer ,
Compliance ,
Cybersecurity ,
ETFs ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Adviser ,
MSRB ,
Municipal Advisers ,
Mutual Funds ,
OCIE ,
Regulation SCI ,
Retail Investors ,
Robo-Advisors ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Self-Regulatory Organizations
On August 7, 2019, the Financial Industry Regulatory Authority ("FINRA") issued a Regulatory Notice (the "Notice") intended to advise broker-dealers about the Securities and Exchange Commission's ("SEC") recently adopted...more
8/21/2019
/ Best Interest Standard ,
Broker-Dealer ,
Disclosure Requirements ,
Fiduciary Duty ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Form CRS ,
Investment Adviser ,
Investment Management ,
New Rules ,
Regulation Best Interest ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Standard of Conduct
The Situation: In a recently released joint statement ("Statement"), the Staffs of the U.S. Securities and Exchange Commission's ("SEC") Division of Trading and Markets, and the Financial Industry Regulatory Authority...more
8/5/2019
/ Blockchain ,
Broker-Dealer ,
Customer Protection Rule ,
Digital Assets ,
Digital Securities ,
Distributed Ledger Technology (DLT) ,
Financial Industry Regulatory Authority (FINRA) ,
Investor Protection ,
Joint Policy Statements ,
Rule 15c3-3 ,
Securities and Exchange Commission (SEC) ,
SIPA
The Situation: In recent years, broker-dealers have been seeking further transparency from the Financial Industry Regulatory Authority ("FINRA") on what constitutes "extraordinary" cooperation with its investigations and when...more
Earlier this year, the Financial Industry Regulatory Authority released its 2019 Annual Risk Monitoring and Examination Priorities Letter. These published priorities, together with the U.S. Securities and Exchange...more