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10 Years On, SEC's Market Access Rule Still Lacks Clarity

The first 10 years of the U.S. Securities and Exchange Commission's Rule 15c3-5, known as the market access rule, have been a textbook example of the principle of regulation by enforcement, resulting in an informal patchwork...more

SEC Holds Kokesh Does Not Impact FINRA Industry Bar

On August 23, 2019, the Securities and Exchange Commission (SEC or Commission) held in In re John M.E. Saad that the US Supreme Court’s decision in Kokesh v. SEC had no impact on the Financial Industry Regulatory Authority’s...more

FINRA Issues New Guidance on Cooperation

On July 11, 2019, the Financial Industry Regulatory Authority (“FINRA”) restated and supplemented prior guidance regarding the circumstances under which FINRA will award credit for “extraordinary cooperation” in...more

SEC Approves Bond Mark-Up Disclosure Rules

On November 17, 2016, the Securities and Exchange Commission (SEC or Commission) approved new rules requiring dealers to disclose on retail customer confirmations their mark-ups and mark-downs on most municipal and corporate...more

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