On May 16, 2024, the Securities and Exchange Commission (SEC) adopted sweeping amendments to Regulation S-P, which governs the privacy of nonpublic consumer personal and financial information for a broad range of financial...more
8/5/2025
/ Broker-Dealer ,
Compliance Dates ,
Consumer Privacy Rights ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Security ,
Final Rules ,
Financial Institutions ,
Incident Response Plans ,
Investment Adviser ,
Recordkeeping Requirements ,
Regulation S-P ,
Securities and Exchange Commission (SEC) ,
Third-Party Service Provider
The Securities Act of 1933, as amended (Securities Act), requires that any offer or sale of securities in the United States must either be registered with the SEC or qualify for an exemption to registration thereunder....more
3/25/2025
/ Broker-Dealer ,
Capital Markets ,
Compliance ,
Financial Regulatory Reform ,
Investment ,
Investors ,
IRS ,
Regulatory Requirements ,
Rule 506 Offerings ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On Nov. 21, Judge Reed O’Connor of the Northern District of Texas vacated the Security and Exchange Commission’s (SEC) newly enacted Rules 3a5-4 and 3a44-2 (collectively, the Dealer Rule), which expanded the scope of who...more
On October 21, 2024, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) released its annual Examination Priorities for fiscal year 2025 (the Report). The Report identifies certain...more
11/14/2024
/ Advisors Act ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Code of Conduct ,
Compliance ,
Enforcement Actions ,
Fiduciary Duty ,
Investment Adviser ,
Private Funds ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC)
On August 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements regarding “off-channel communications.”1 As part of its Off-Channel Communications Initiative,2 the SEC settled...more
On April 3, 2024, the U.S. Securities and Exchange Commission (SEC) announced yet another settlement regarding “off-channel communications.” As we have previously written about, settlements of this type have become...more
On January 16, the Securities and Exchange Commission (SEC) announced an $18 million settlement order (Order) with J.P. Morgan Securities LLC (JPMS) that finds that the language of release agreements JPMS entered into with...more
The U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) recently released its annual Examination Priorities for fiscal year 2024 (the Report). The Report underlines the Division’s focus on...more
11/14/2023
/ Broker-Dealer ,
Cybersecurity ,
Disclosure ,
Fiduciary Duty ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Marketing ,
Policies and Procedures ,
Portfolio Managers ,
Private Funds ,
Registered Investment Advisors ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC)
On March 15, 2023, the Securities and Exchange Commission (“SEC”) issued three releases proposing (i) amendments to Regulation S-P (“Regulation S-P Proposal”)1, (ii) amendments to Regulation SCI (“Regulation SCI Proposal”)2,...more
3/30/2023
/ Broker-Dealer ,
Cybersecurity ,
Electronically Stored Information ,
Incident Response Plans ,
Investment Adviser ,
Investment Companies ,
Policies and Procedures ,
Proposed Amendments ,
Regulation S-P ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
On February 7, 2023, the U.S. Securities and Exchange Commission (“SEC”) Division of Examinations (the “Division”) released its annual Priorities Report1 for upcoming examinations of registered investment advisers...more
2/17/2023
/ Anti-Money Laundering ,
Broker-Dealer ,
Conflicts of Interest ,
Cryptoassets ,
Customer Protection Rule ,
Cyber Crimes ,
Cybersecurity ,
Emerging Technologies ,
Environmental Social & Governance (ESG) ,
Fiduciary Duty ,
Investment Adviser ,
Marketing ,
Popular ,
Portfolio Managers ,
Private Funds ,
Registered Investment Advisors ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC)
On December 5, 2022, the Division of Examinations (EXAMS) of the Securities and Exchange Commission (SEC) issued a Risk Alert regarding recently observed compliance issues with respect to Regulation S-ID. Under Regulation...more
On September 27, 2022, regulators from the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) handed out over $1.8 billion in fines to financial institutions in connection with...more
10/6/2022
/ Books & Records ,
Broker-Dealer ,
CFTC ,
Commercial Electronic Messages ,
Electronic Communications ,
Financial Institutions ,
Fines ,
Investment Adviser ,
OCIE ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Technology ,
Training
Summaries of recent legislative and regulatory developments with respect to:
•SEC’s 2022 Examination Priorities • Proposed Amendments to Form PF Requirements-
•Proposed New Rules Applicable to Private Fund Advisers and...more
5/5/2022
/ Anti-Money Laundering ,
Beneficial Owner ,
Broker-Dealer ,
CFTC ,
Commodity Trading Advisors (CTAs) ,
CPOs ,
Cryptocurrency ,
Cybersecurity ,
Department of Labor (DOL) ,
Digital Assets ,
Employee Retirement Income Security Act (ERISA) ,
Environmental Social & Governance (ESG) ,
Fiduciary Rule ,
Foreign Investment ,
General Data Protection Regulation (GDPR) ,
Investment Adviser ,
Investment Funds ,
NFA ,
Proxy Voting ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Threshold Requirements
On March 30, the Office of Compliance Inspections and Examinations of the U.S. Securities and Exchange Commission (SEC) published its examination priorities for 2022 (the Priorities), which discuss its examination approach...more
4/29/2022
/ Broker-Dealer ,
Cryptocurrency ,
Emerging Technology Companies ,
Environmental Social & Governance (ESG) ,
Financial Institutions ,
Financial Services Industry ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
OCIE ,
Registered Investment Advisors ,
Regulation Best Interest ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC)
Summaries of recent legislative and regulatory developments with respect to:
•The SEC’s Examination Priorities for 2021-
•The SEC’s Focus on Digital Asset Securities-
•The SEC’s New Marketing Rule... ...more
4/1/2021
/ Accredited Investors ,
Anti-Money Laundering ,
BEA ,
Broker-Dealer ,
CARES Act ,
CFIUS ,
Chief Compliance Officers ,
Client Funds ,
Common Reporting Standard (CRS) ,
Compliance ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Digital Assets ,
Disclosure ,
Employee Retirement Income Security Act (ERISA) ,
Environmental Social & Governance (ESG) ,
EU ,
Financial Fraud ,
Financial Industry Regulatory Authority (FINRA) ,
FinTech ,
Foreign Investment ,
Form CRS ,
General Data Protection Regulation (GDPR) ,
IARD ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Portfolios ,
Net Operating Losses ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Safe Harbors ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
Unauthorized Transactions
On November 2, the Securities and Exchange Commission’s Division of Enforcement (the Division) published its 2020 Annual Report (the Report), which details the Division’s fiscal year (FY) ending September 30, 2020,...more
11/10/2020
/ Broker-Dealer ,
Coronavirus/COVID-19 ,
Disgorgement ,
Enforcement ,
Enforcement Actions ,
Financial Fraud ,
Investment Adviser ,
OCIE ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
What You Need To Know:
•The SEC proposes to exempt two types of Finders from broker-dealer registration pursuant if they satisfy certain conditions.
•Tier I Finders may provide potential investors’ contact information to...more
10/20/2020
/ Broker-Dealer ,
Capital Investments ,
Disclosure ,
Exemptions ,
Finders ,
Hedge Funds ,
Investors ,
Private Equity Funds ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Third Party Funding ,
Unregistered Brokers ,
Venture Capital ,
Written Agreements