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Modernizing FINRA Rules for Member Workplaces: A Call for Comments

FINRA previously announced in Regulatory Notice 25-04 that it is launching a broad review to modernize its rules regarding member firms and associated persons and identified the modern workplace as its area of initial focus....more

FINRA Proposes Single Rule to Replace FINRA Rules 3270 and 3280

FINRA has proposed a single, streamlined rule (the Proposed Rule) to replace FINRA Rule 3270 (Outside Business Activities of Registered Persons) and FINRA Rule 3280 (Private Securities Transactions of an Associated Person)...more

Deciphering FinCEN’s New Anti-Money Laundering Rules for Advisers

On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to anti-money laundering/countering the financing of terrorism...more

FINCEN’s AML Proposal: An Overview for Investment Advisers

Earlier this year, the US Department of the Treasury’s (Treasury’s) Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposal) that would subject investment advisers to anti-money...more

Remote and Hybrid Work: FINRA Announces Effective Dates of New Rules

The die is cast: FINRA has published Regulatory Notice 24-02 (RN 24-02) announcing the effective dates and other key dates and considerations for its recently adopted Residential Supervisory Location (RSL) and Remote...more

New York Weighs Requiring Public Disclosure of LLC Ownership Information

The New York State Assembly recently passed the LLC Transparency Act (the LLC Act). If signed into law by New York Governor Kathy Hochul, the LLC Act would require limited liability companies (LLCs) formed or registered to do...more

An End to the Paper Chase? Proposed Bill Could Greatly Expand SEC Registrants’ E-Delivery Use

The House Committee on Financial Services passed the Improving Disclosure for Investors Bill of 2023 on April 26, 2023 with bipartisan support. If passed by Congress and signed into law, the bill could alter the regulatory...more

FinCEN Proposes Applications for FinCEN Identifier and BOI Reporting Pursuant to Final Rule

The US Treasury’s Financial Crimes Enforcement Network (FinCEN) published notices on January 17 seeking public comment on two proposals: (1) the application document that individuals would use to obtain a FinCEN identifier...more

FinCEN Proposes New Rule on Beneficial Ownership Information Access and Safeguards for Corporate Transparency Act

The US Treasury’s Financial Crimes Enforcement Network (FinCEN) recently proposed a new rule (the Proposed Rule) regarding beneficial ownership information access and safeguards pursuant to the Corporate Transparency Act....more

Fincen Establishes Beneficial Ownership Reporting Requirements to Implement Corporate Transparency Act

On September 30, the US Treasury’s Financial Crimes Enforcement Network (FinCEN) published, in the Federal Register, a final rule (Final Rule) that establishes beneficial ownership information (BOI) reporting requirements...more

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