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FINRA Kicks Off the Holiday Season With a Proposal to Permit the Use of Some Projections and Targeted Returns

FINRA has offered a gift to member firms and fund managers just in time for the holiday season — but like a new puppy, the gift comes with a lot of responsibility. FINRA filed a proposed rule change to amend FINRA Rule 2210...more

A Closer Look at the SEC’s Cybersecurity Rules for Covered Entities and Market Entities

The SEC is continuing its campaign to overhaul cybersecurity, cyber incident reporting, and privacy controls and requirements for financial services industry registrants, their service providers, and corporate America...more

FINRA Asks How to Improve Capital Formation Rules; Public Companies and Fund Managers May Have Ideas

In Regulatory Notice 23-09, FINRA provides an update on actions it currently has under way to promote capital formation and the capital-raising process. FINRA also requests comment regarding whether there are other changes to...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

Broker-Dealer Compliance With Revamped Recordkeeping Requirements Begins May 3, 2023; FINRA Publishes Chart of “Most Significant...

The SEC recently amended Exchange Act Rule 17a-4 by adopting new recordkeeping requirements for broker-dealers. Most notably, the SEC will no longer require broker-dealers to maintain records in “write once, read many” or...more

FINRA Reminds Firms of Trusted Contact Person Requirement, Benefits, and Related Effective Practices

FINRA remains very focused on preventing financial exploitation of seniors and other investors. Firms can expect to see senior investor protection as a key area of focus in the forthcoming 2023 Report on FINRA’s Examination...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

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

FINRA Focused on Registered Reps Named as Beneficiaries and Trustees for Customer Accounts

​​​​​​​FINRA recently highlighted Rule 3241 in the 2023 Regulatory Element Learning Plan. Rule 3241 became effective in early February 2021 and prohibits a registered person from being named as a beneficiary, executor, or...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

BD and IA Conflicts of Interest: SEC Staff Says Don’t Set It (Them) and Forget It (Them)

​​​​​​​SEC staff recently served up a juicy staff bulletin covering the standards of conduct for broker-dealer and investment adviser conflicts of interest. The staff bulletin includes 13 Q&As categorized into five different...more

FINRA Proposes to Publicly Identify “Restricted Firms” on BrokerCheck

BrokerCheck is the database through which FINRA publishes licensing, registration, and disciplinary history of brokerage industry firms and their personnel. BrokerCheck does not currently specify whether a particular firm is...more

Cybersecurity Remains a Key Focus Area for the SEC and FINRA

Cybersecurity and technology governance remain a top area of focus for the SEC and FINRA, as the regulators continue to concentrate on improving the overall cybersecurity posture and resiliency of the financial sector. FINRA...more

FINRA 2022 Exam Report Spotlight: Communications with the Public

It came as no surprise that FINRA’s 2022 Examination and Risk Monitoring Program Report highlighted communications with the public as a continued area of focus. The primary theme across this focus area relates to the...more

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 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

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

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

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