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SEC Sends Second Message to Private-Fund Sponsors on Audit Obligations Under Custody Rule Through Enforcement Actions

On September 5, 2023, almost one year since its first flurry of similar Custody Rule actions,  the SEC announced settlements with five SEC-registered investment advisers to private funds with respect to alleged violations of...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

FINRA 2023 Examination and Risk Monitoring Report Highlights Numerous Risk Areas for Brokers

On January 10, 2023, FINRA published the 2023 Report on FINRA’s Examination and Risk Monitoring Program. The Report serves as a resource for firms to use to bolster their compliance programs and provides a roadmap of FINRA’s...more

FINRA Provides Update on Options Account Opening and Trading Sweep Exam Findings

FINRA recently provided an update on the August 2021 review of its members’ practices and controls related to the opening of options accounts and related areas, including account supervision, communications, and diligence. ...more

FINRA, Nasdaq, and NYSE Warn Firms of Pump-and-Dump Schemes Following IPOs of Small-Cap Issuers

FINRA, Nasdaq, and NYSE published separate notices to alert their members about recent observations related to initial public offerings (IPOs) for certain small capitalization (small-cap) issuers listed on US stock exchanges...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

SEC Brings First Ever Regulation Best Interest Litigation Against Broker-Dealer and Its Personnel

The U.S. Securities and Exchange Commission recently charged a broker-dealer and five of its registered representatives with violating Regulation Best Interest (“Reg. BI”) related to recommendations and sales of an unrated,...more

FINRA Reminds CCOs About Potential Supervisory Liability

FINRA recently published Regulatory Notice 22-10 reminding firms of the scope of Rule 3110 (Supervision) and the potential liability of Chief Compliance Officers for failure to reasonably discharge supervisory...more

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