The U.S. Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have each published their annual examination priorities for 2021, signaling areas of scrutiny that broker-dealers should...more
4/9/2021
/ Anti-Money Laundering ,
Broker-Dealer ,
Compliance ,
Conflicts of Interest ,
Cybersecurity ,
Data Protection ,
Financial Industry Regulatory Authority (FINRA) ,
Phishing Scams ,
Ransomware ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
On December 16, 2020, FINRA issued Regulatory Notice 20-42 announcing a retrospective rule review to seek comments on “Lessons From the COVID-19 Pandemic.” In the notice, FINRA requests interested parties to provide...more
Thwarting the financial exploitation of seniors and other vulnerable investors has been an increasing focus of several financial regulators in recent years, including the Financial Industry Regulatory Authority (“FINRA”). In...more
On Monday, March 9, 2020, FINRA issued Regulatory Notice 20-08, titled Pandemic-Related Business Continuity Planning, Guidance and Regulatory Relief, to provide guidance and regulatory relief to its members confronting...more
It’s been nearly five months since the Securities and Exchange Commission (“SEC”) approved Regulation Best Interest: The Broker-Dealer Standard of Conduct (“Reg BI”). As discussed in our June 27, 2019 Client Alert, Reg BI...more
11/1/2019
/ Broker-Dealer ,
Fiduciary Duty ,
Financial Industry Regulatory Authority (FINRA) ,
Form CRS ,
Investment Adviser ,
Investment Management ,
Investors ,
Legislative Agendas ,
Regulation Best Interest ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Transactions ,
Standard of Conduct
FINRA yesterday issued long-anticipated guidance concerning credit for extraordinary cooperation in the context of enforcement investigations. Like its government counterparts, FINRA hopes to incentivize member firms that go...more
On June 5, 2019, the Securities and Exchange Commission (“SEC”) voted to adopt Regulation Best Interest: The Broker-Dealer Standard of Conduct (hereinafter, “Regulation BI”), requiring broker-dealers and their associated...more
Recently, the Financial Industry Regulatory Authority (“FINRA”) and the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) separately issued important guidance regarding customer communications surrounding the...more
5/3/2019
/ Broker-Dealer ,
Confidential Communications ,
Consumer Privacy Rights ,
Disclosure Requirements ,
Financial Industry Regulatory Authority (FINRA) ,
New Guidance ,
OCIE ,
Personally Identifiable Information ,
Privacy Policy ,
Registered Investment Advisors ,
Regulation S-P ,
Securities and Exchange Commission (SEC) ,
Security and Privacy Controls
On January 22, 2019, FINRA released its 2019 Annual Risk Monitoring and Examination Priorities Letter (the “Priorities Letter”). Late last year, as part of FINRA360 – the organization’s ongoing improvement initiative – FINRA...more
2/22/2019
/ Anti-Money Laundering ,
BSA/AML ,
Examination Priorities ,
Financial Industry Regulatory Authority (FINRA) ,
FinCEN ,
Fixed Income Investments ,
Initial Coin Offering (ICOs) ,
Online Distribution ,
Online Platforms ,
Popular ,
Regulation D ,
Risk Management ,
Rule 506(c) ,
Token Sales
On January 28, 2019, FINRA announced a novel leniency initiative that will offer no-fine enforcement resolutions for member firms that self-report supervisory deficiencies related to recommendations of 529 savings plans and...more
On December 20, 2018, the Financial Industry Regulatory Authority (FINRA) issued a “Report on Selected Cybersecurity Practices” (the “Report”) as part of its ongoing efforts to assist broker-dealer firms in developing...more
While many of us were winding down the year focused on the December holidays, the U.S. Department of Justice, the SEC, FINRA, and FinCEN were busy delivering a flurry of messages to the broker-dealer industry about AML...more