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Disclosure Requirements Financial Services Industry Enforcement Actions

Troutman Pepper Locke

FINRA Continues to Scrutinize Customer Facing Communications on Crypto Offerings

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On July 16, TradeStation Securities, Inc., a member firm of the Financial Industry Regulatory Authority (FINRA), submitted a Letter of Acceptance, Waiver, and Consent (AWC) to FINRA’s Department of Enforcement. This AWC...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 29, 2025)

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FTC Obtains Temporary Restraining Order and Asset Freeze Against Seven Debt Relief Companies and Their Owners for Allegedly Deceptive Practices. On July 14, the FTC filed a complaint and motion for temporary restraining order...more

Troutman Pepper Locke

California’s DFPI Brings First Enforcement Action Under California’s Digital Financial Assets Law

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On June 25, the California Department of Financial Protection and Innovation (DFPI) entered a consent order with Coinme, Inc., a cryptocurrency “ATM” operator, for noncompliance with the California’s Consumer Financial...more

Paul Hastings LLP

SFDR Update: A Step Up in Scrutiny

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In recent weeks, EU regulators have issued several updates clearly indicating that, while the Sustainable Finance Disclosure Regulation (SFDR) remains subject to review and likely substantial revision at the end of 2025,...more

Eversheds Sutherland (US) LLP

Asset managers should be aware of the recent GAO report on Artificial Intelligence – Use and Oversight in Financial Services

The report outlines the advantages and potential risks associated with AI, while also offering insight into current regulatory perspectives on its use. The GAO’s findings have been shared with the SEC and could influence...more

K&L Gates LLP

Key Takeaways From the UK Financial Conduct Authority's Revised Enforcement Guide

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Following a two-part consultation, which began in February 2024 (i.e., CP 24/2 and CP 24/2: Part 2) and was accompanied by a Policy Statement (PS25/5) setting out the UK Financial Conduct Authority’s (FCA) consultation...more

Hogan Lovells

UK Financial Conduct Authority publishes its revised Enforcement Guide

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The UK’s Financial Conduct Authority (FCA) has published Policy Statement PS25/5, Our Enforcement Guide and greater transparency of our enforcement investigations, setting out the changes it is making to its Enforcement Guide...more

Porter Hedges LLP

SEC Shifts Focus to “Rooting Out” AI Abuse

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The Securities and Exchange Commission (SEC) has recently focused on “rooting out” the misuse of artificial intelligence (AI) by publicly traded companies and brokerage firms. On February 20, 2025, the SEC established the...more

Davies Ward Phillips & Vineberg LLP

A Strong Signal: AMF Adopts a Policy Supporting Self-Reporting and Cooperation

The Autorité des marchés financiers (AMF), the body responsible for enforcing Québec’s legislation concerning the financial sector, recently adopted a Self-Reporting and Cooperation Policy. The policy, adopted on May 20,...more

WilmerHale

FCA's Regulatory Plans Signal Cause For Cautious Optimism

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Supporting growth, fighting crime, helping consumers and being a smarter regulator: These are the four predictable priorities identified in the Financial Conduct Authority's 2025-2030 strategy document, released on March 25. ...more

Troutman Pepper Locke

First Circuit Questions Materiality in SEC's Case Against Commonwealth Equity Services

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On April 1, the U.S. Court of Appeals for the First Circuit vacated a summary judgment ruling in favor of the Securities and Exchange Commission (SEC) against Commonwealth Equity Services, LLC, also known as Commonwealth...more

Davis Wright Tremaine LLP

CFTC Eliminates PTMMM Disclosure Requirements for Swap Entities

On April 4, 2025, the CFTC's Division of Market Participants issued No-Action Letter 25-09 regarding the controversial Pre-Trade Mid-Market Mark ("PTMMM") requirements in CFTC Regulation 23.431, effectively eliminating the...more

Katten Muchin Rosenman LLP

After 12 Enforcement Actions and 9 No-Action Letters, CFTC Staff Effectively Repeals the Pre-Trade Mid-Market Mark Disclosure...

The Commodity Futures Trading Commission's (CFTC or Commission) Market Participants Division (MPD) issued Letter 25-09, which effectively eliminates the pre-trade mid-market mark (PTMMM) disclosure requirement for uncleared...more

King & Spalding

Rebranding of SEC Cyber Unit Reflects Shift in Enforcement Priorities

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On Thursday, February 20, the U.S. Securities and Exchange Commission (“SEC”) announced that it created a Cyber and Emerging Technologies Unit (“CETU”) to combat cyber-focused financial misconduct. The announcement reflects a...more

Cadwalader, Wickersham & Taft LLP

Regulation in Flux, March 2025 - The UK’s FCA Publishes Bulletin on Leaks of Market Sensitive Information

In Primary Market Bulletin 54, the Financial Conduct Authority ("FCA") addresses concerns about deliberate, unintentional and unlawful disclosure of market sensitive information during ongoing M&A transactions. Leaks to the...more

Latham & Watkins LLP

Recent Developments for UK PLCs - March 2025

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On 6 February 2025, the House of Lords Financial Services Regulation Committee published a report titled “Naming and shaming: how not to regulate”....more

Hogan Lovells

UK FCA “naming and shaming” proposals: the House of Lords steps in.

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The House of Lords Financial Services Regulation Committee (“FSRC”) has published a report on the Financial Conduct Authority’s (“FCA”) proposals to change its approach to announcing enforcement investigations, from...more

A&O Shearman

House of Lords Committee report on proposal to publicise enforcement investigations

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The House of Lords Financial Services Regulation Committee (FSR Committee) published a report on the Financial Conduct Authority's (FCA's) proposal to publicise enforcement investigations, in the spirit of "naming and...more

K&L Gates LLP

Asset Management Regulatory Year in Review 2024

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2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more

Proskauer - Regulatory & Compliance

SEC Extends Compliance Date for Short Sale Reporting Rule to 2026

On February 6, 2025, the SEC announced that it was providing a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act of 1934 (the “Exchange Act”), which establishes a mandatory short reporting...more

Mayer Brown Free Writings + Perspectives

ICI Urges SEC to Delay Short-Sell Reporting Rules Amid Compliance Uncertainty

The Investment Company Institute (ICI) has asked the Securities and Exchange Commission (SEC) in a comment letter to delay enforcement of its new short sale disclosure rules (the “Short Sale Final Rules”) until additional...more

A&O Shearman

Updates on OJK Regulation 45/2024

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On December 27, 2024 the Indonesia Financial Service Authority (Otoritas Jasa Keuangan or the OJK) issued OJK Regulation No. 45 of 2024 on Development and Enhancement of Issuers and Public Companies (OJK Regulation 45/2024). ...more

Ballard Spahr LLP

CFPB orders remittance transfer provider to pay almost $2.5 million for alleged illegal activities

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On January 30, 2025, the CFPB ordered Wise, an international remittance company, to pay almost $2.5 million in connection with allegations of illegal activities, including advertising inaccurate fees and failing to properly...more

Robinson Bradshaw

Regulatory Uncertainty Regarding Private Funds and Artificial Intelligence Utilization

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As in most industries, private fund sponsors are increasingly assessing and beginning to adopt artificial intelligence-powered tools to rapidly analyze large volumes of data, identify trends and patterns and to generally make...more

K&L Gates LLP

Europe: Are the UK FCA’s Revised “Name and Shame” Proposals an Improvement?

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In November 2024, the UK FCA released a Consultation which seeks to clarify its proposed approach to publicising ongoing enforcement action—dubbed the “name and shame” plan—and to assure the wider market of the plan’s...more

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