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Associated Persons

DarrowEverett LLP

Private Placements in Florida Just Got Easier: Here’s How

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Florida recently implemented amendments to its Securities and Investor Protection Act (“Chapter 517”), bringing significant changes to the regulatory framework governing private placements, investment advisors, and exemptions...more

Latham & Watkins LLP

NFA to Require Swap Proficiency Examination for Swap Associated Persons

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The NFA has implemented requirements that all swap associated persons take and pass a swap proficiency examination by January 31, 2021. Key Points: ..As of January 31, 2021, all swap associated persons will need to take...more

Eversheds Sutherland (US) LLP

NFA proposes proficiency requirements for Swap APs

On March 5, 2019, the National Futures Association (NFA) submitted to the Commodity Futures Trading Commission (CFTC or Commission) proposed amendments to NFA Bylaw 301 and NFA Compliance Rule 2-24 and the proposed...more

UB Greensfelder LLP

Does FINRA Have Jurisdiction Over Me?

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Does FINRA have jurisdiction over me? This is a question that I regularly field at the outset of regulatory engagements. My answer differs depending on a number of factors, including the nature of a person’s role and duties...more

Skadden, Arps, Slate, Meagher & Flom LLP

"'Failure to Prevent': The Implications for Global Financial Institutions"

The U.K. government is set to introduce a new corporate criminal offence, based on the strict liability of the entity in question. It almost certainly will come into force in 2017, once the Criminal Finances Bill (Bill) is...more

Morgan Lewis

Broker-Lite: FINRA Built It, But Will They Come?

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On August 18, 2016, the US Securities and Exchange Commission (SEC) approved a new Financial Industry Regulatory Authority (FINRA) rule series intended as a “lite” framework for the registration and regulation of brokers that...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume XI, Issue 26

SEC/CORPORATE – SEC Division of Corporation Finance Issues C&DIs on Application of Rule 701 – On June 23, the Staff of the Division of Corporation Finance (Staff) of the Securities and Exchange Commission...more

Akin Gump Strauss Hauer & Feld LLP

Anti-Corruption Summit: Extending Corporate Liability for Economic Crimes?

In a keynote address at the London Anti-Corruption Summit, Prime Minister David Cameron raised the possibility of new U.K. legislation to make corporations liable for “failure to prevent” fraud or money-laundering offenses...more

WilmerHale

Registration of Associated Persons with Algorithmic Trading Responsibilities

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On April 7, 2016, the Securities and Exchange Commission (“SEC”) approved the Financial Industry Regulatory Authority's (“FINRA”) proposal to amend NASD Rule 1032 (Categories of Representative Registration) to require...more

Katten Muchin Rosenman LLP

The SEC Approves a FINRA Rule Amendment Requiring Registration of Associated Persons Who Design or Develop Algorithmic Trading...

On April 7, the Securities and Exchange Commission (SEC) approved amendments to NASD Rule 1032(f) which will require registration as Securities Traders of associated persons who are primarily responsible for the design,...more

Eversheds Sutherland (US) LLP

FINRA’s Projected 2015 Fines: Not Keeping Pace With 2014’s Total, But Still a Blockbuster Year

Despite a slowdown in the fines reported in 2015, the Financial Industry Regulatory Authority (FINRA) has continued to flex its enforcement muscle so far this year. During the first half of 2015, FINRA reported $37.5 million...more

Katten Muchin Rosenman LLP

SEC Adopts Registration Rules for Security-Based Swap Dealers and Major Security-Based Swap Participants

On August 5, the Securities and Exchange Commission adopted new registration rules for security-based swap dealers and major security-based swap participants (SBS entities). In general, an SBS entity would register by filing...more

Katten Muchin Rosenman LLP

FINRA Proposes Rule Governing Personal Securities Transactions of Associated Persons

On July 31, the Financial Industry Regulatory Authority filed a proposed rule change with the Securities and Exchange Commission to adopt FINRA Rule 3210 (Accounts At Other Broker-Dealers and Financial Institutions) in the...more

Katten Muchin Rosenman LLP

FINRA Seeks Comment on Proposal Requiring Registration of Associated Persons Who Develop Algorithmic Trading Strategies

Introduction - As part of its ongoing market structure initiatives related to, among other things, automated trading activities, the Financial Industry Regulatory Authority (FINRA) has issued a proposal that would...more

Burr & Forman

SEC Approves FINRA Rule Regarding Investigation and Verification of Registration Applicants

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After seeking comments last fall, the Securities and Exchange Commission (“SEC”) recently approved the Financial Industry Regulatory Authority’s (“FINRA”) proposed rule governing member firms’ verification and investigation...more

Foley & Lardner LLP

"Smoking Gun" Comments Serve as an Important Reminder of the ADA’s Protection Against Associational Discrimination

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Most employers are well aware that the Americans with Disabilities Act (ADA) protects qualified individuals with disabilities against discrimination on the basis of disability and requires employers to provide reasonable...more

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