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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

SEC Staff Provides Guidance on Broker-Dealer and Investment Adviser Standards of Conduct For Account and Rollover Recommendations...

U.S. Securities and Exchange Commission staff recently published a bulletin reiterating the standards of conduct applicable to broker-dealers and investment advisers when making account recommendations to retail investors....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 Focus on Cybersecurity Begins to Take Shape

The U.S. Securities and Exchange Commission is implementing a campaign to overhaul the agency’s expectations around cybersecurity and cyber incident reporting for the financial services industry and corporate America...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

SEC Proposes Alternative to “WORM” Books and Records Retention for Broker-Dealers and Security-Based Swap Entities

On November 18, 2021, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments to Rules 17a-4 and 18a-6 under the Securities Exchange Act of 1934 related to recordkeeping requirements for broker-dealers and...more

SEC Staff Provides Form CRS Observations, Expectations, and Best Practices

On December 17, 2021, the staff of the U.S. Securities and Exchange Commission issued a statement regarding Form CRS disclosures required of SEC-registered broker-dealers and investment advisers who offer services to retail...more

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