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SEC Outlines 2024 Examination Priorities

The priorities highlight emerging and core risk areas for investment advisers, broker-dealers, and other entities, including cybersecurity and crypto assets. On October 16, 2023, the Securities and Exchange Commission’s...more

New Federal Exemption Changes the Registration Landscape for M&A Brokers

The narrower M&A broker exemption supersedes the 2014 M&A broker no-action letter while leaving state-level restrictions and foreign M&A broker relief unaffected. On March 29, 2023, the Securities Exchange Act of 1934...more

SEC Proposes to Expand Interpretation of “Dealer” and “Government Securities Dealer” Definitions

On March 28, 2022, the US Securities and Exchange Commission (SEC) proposed rules (Proposing Release) that would require securities market participants that engage in dealer-like activities - such as a proprietary trading...more

When Are CCOs on the Hook? FINRA Offers Guidance on CCO Liability

Guidance clarifies assessment of liability under Rule 3110, including designation as supervisor, application of reasonableness standard, and factors for and against charging compliance officials. On March 17, 2022, the...more

SEC Staff Issues Key Considerations on LIBOR Transition

As a major LIBOR transition milestone approaches, a Staff Statement provides key considerations for market participants regarding their obligations. On December 7, 2021, the Staff of the Securities and Exchange...more

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